{
  "document_metadata": {
    "page_number": "46",
    "document_number": "621",
    "date": "02/25/22",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 621 Filed 02/25/22 Page 46 of 51\nmade any showing that the preindictment delay was an intentional device designed by the Government to gain a tactical advantage.\"); United States v. Martinez, No. 94 Cr. 219 (RPP), 1995 WL 10849, at *4 (S.D.N.Y. Jan. 12, 1995) (“In order to establish improper delay by the Government in filing an indictment, a defendant must show that the delay was the result of an intentional device of the Government to gain tactical advantage over the accused.” (citing United States v. Hoo, 825 F.2d 667, 671 (2d Cir. 1987))). Indeed, some version of the phrase “deliberate device” and “tactical advantage” is found in nearly every Second Circuit decision on the issue. See, e.g., Alameh, 341 F.3d at 176 (“intentionally used delay to gain unfair tactical advantage”); Cornielle, 171 F.3d at 752 (requiring “intentional device” to gain “tactical advantage”); Lawson, 683 F.2d at 694 (delay not “engineered by the government for an improper purpose, such as gaining a tactical advantage”); Snyder, 668 F.2d at 689; United States v. Watson, 599 F.2d 1149, 1156 n.5 (2d Cir. 1979); United States v. Tanu, 589 F.2d 82, 89 (2d Cir. 1978); United States v. Laurenti, 581 F.2d 37, 40 n.11 (2d Cir. 1978); United States v. Hillegas, 578 F.2d 453, 460 (2d Cir. 1978).\n4. Discussion\nBecause the defendant has failed to establish prejudice, the Court need not address the defendant’s specious arguments that the Government’s purpose in any alleged pre-indictment delay was improper or designed to gain any sort of tactical advantage. See Pierre-Louis, 2018 WL 4043140, at *5. In any event, in denying the defendant’s pre-trial motions and supplemental pre-trial motions, the Court noted the absence of “evidence that the Government’s delay in bringing these charges was designed to thwart Maxwell’s ability to prepare a defense.” (Dkt. No. 207 at 17; Dkt. No. 317 at 10). That remains true.\n45\nDOJ-OGR-00009608",
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    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 621 Filed 02/25/22 Page 46 of 51",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "made any showing that the preindictment delay was an intentional device designed by the Government to gain a tactical advantage.\"); United States v. Martinez, No. 94 Cr. 219 (RPP), 1995 WL 10849, at *4 (S.D.N.Y. Jan. 12, 1995) (“In order to establish improper delay by the Government in filing an indictment, a defendant must show that the delay was the result of an intentional device of the Government to gain tactical advantage over the accused.” (citing United States v. Hoo, 825 F.2d 667, 671 (2d Cir. 1987))). Indeed, some version of the phrase “deliberate device” and “tactical advantage” is found in nearly every Second Circuit decision on the issue. See, e.g., Alameh, 341 F.3d at 176 (“intentionally used delay to gain unfair tactical advantage”); Cornielle, 171 F.3d at 752 (requiring “intentional device” to gain “tactical advantage”); Lawson, 683 F.2d at 694 (delay not “engineered by the government for an improper purpose, such as gaining a tactical advantage”); Snyder, 668 F.2d at 689; United States v. Watson, 599 F.2d 1149, 1156 n.5 (2d Cir. 1979); United States v. Tanu, 589 F.2d 82, 89 (2d Cir. 1978); United States v. Laurenti, 581 F.2d 37, 40 n.11 (2d Cir. 1978); United States v. Hillegas, 578 F.2d 453, 460 (2d Cir. 1978).",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "4. Discussion",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Because the defendant has failed to establish prejudice, the Court need not address the defendant’s specious arguments that the Government’s purpose in any alleged pre-indictment delay was improper or designed to gain any sort of tactical advantage. See Pierre-Louis, 2018 WL 4043140, at *5. In any event, in denying the defendant’s pre-trial motions and supplemental pre-trial motions, the Court noted the absence of “evidence that the Government’s delay in bringing these charges was designed to thwart Maxwell’s ability to prepare a defense.” (Dkt. No. 207 at 17; Dkt. No. 317 at 10). That remains true.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "45",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00009608",
      "position": "footer"
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  ],
  "entities": {
    "people": [
      "Martinez",
      "Hoo",
      "Alameh",
      "Cornielle",
      "Lawson",
      "Snyder",
      "Watson",
      "Tanu",
      "Laurenti",
      "Hillegas",
      "Pierre-Louis",
      "Maxwell"
    ],
    "organizations": [
      "Government",
      "Court",
      "Second Circuit"
    ],
    "locations": [
      "S.D.N.Y."
    ],
    "dates": [
      "02/25/22",
      "Jan. 12, 1995",
      "1978",
      "1979"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 621",
      "94 Cr. 219 (RPP)",
      "1995 WL 10849",
      "341 F.3d",
      "171 F.3d",
      "683 F.2d",
      "668 F.2d",
      "599 F.2d",
      "589 F.2d",
      "581 F.2d",
      "578 F.2d",
      "2018 WL 4043140",
      "Dkt. No. 207",
      "Dkt. No. 317"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is mostly printed, with no handwritten content or stamps visible. The document is well-formatted and legible."
}