{
  "document_metadata": {
    "page_number": "14",
    "document_number": "398",
    "date": "10/29/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 398 Filed 10/29/21 Page 14 of 52 The government contends that reveal \"defendant's intent and motive,\" but their argument is defies logic. This is exactly the type of evidence forbidden by Rule 404(b). See United States v. Angelilli, 660 F.2d 23, 40-41 (2d Cir. 1981) (\"While we conclude that the custom and practice evidence was admissible for the purposes we have discussed, we agree with the defendants that Rule 404(b) barred its use to prove that the individual defendants acted in conformity with the custom and practice. ...\"). Even if the Court overlooks the government's failure to provide notice, absence of relevance to the charged conspiracy, and the government's failure to set forth a non-propensity ground for admissibility, should also be excluded under Rules 401 and 403, as they do not tend to make any fact of consequence more or less probable, and their probative value is substantially outweighed by the danger of unfair prejudice and confusing the issues. 8 DOJ-OGR-00005969",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 398 Filed 10/29/21 Page 14 of 52",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "The government contends that reveal \"defendant's intent and motive,\" but their argument is defies logic.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "This is exactly the type of evidence forbidden by Rule 404(b). See United States v. Angelilli, 660 F.2d 23, 40-41 (2d Cir. 1981) (\"While we conclude that the custom and practice evidence was admissible for the purposes we have discussed, we agree with the defendants that Rule 404(b) barred its use to prove that the individual defendants acted in conformity with the custom and practice. ...\").",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Even if the Court overlooks the government's failure to provide notice, absence of relevance to the charged conspiracy, and the government's failure to set forth a non-propensity ground for admissibility, should also be excluded under Rules 401 and 403, as they do not tend to make any fact of consequence more or less probable, and their probative value is substantially outweighed by the danger of unfair prejudice and confusing the issues.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "8",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00005969",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [],
    "organizations": [],
    "locations": [],
    "dates": [
      "10/29/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 398",
      "DOJ-OGR-00005969"
    ]
  },
  "additional_notes": "The document appears to be a court filing with redactions. The text is mostly printed, with some blacked-out sections."
}