{
  "document_metadata": {
    "page_number": "5",
    "document_number": "392",
    "date": "10/29/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
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  "full_text": "Case 1:20-cr-00330-PAE Document 392 Filed 10/29/21 Page 5 of 8 On June 23, 2021, almost twenty years after the alleged events, and 14 years after did not identify Ms. Maxwell as the perpetrator of any crime, the Government presented with a series of photographs, attached as Exhibit A. The photographic identification procedure used was the functional equivalent of a one-on-one show-up. Any identification is tainted and should therefore be suppressed by the Court. ARGUMENT A defendant's right to due process includes the right not to be the object of suggestive police identification procedures that create \"a very substantial likelihood of irreparable misidentification.\" Simmons v. United States, 390 U.S. 377, 384 (1968); accord Neil v. Biggers, 409 U.S. 188, 198 (1972); see also Manson v. Brathwaite, 432 U.S. 98, 106 n.9, 114 (1977). This principle applies both to show-ups, see, e.g., Stovall v. Denno, 388 U.S. 293 (1967), and to photographic identifications. Simmons v. United States, 390 U.S. 377, 384 (1968). 2 DOJ-OGR-00005742",
  "text_blocks": [
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      "content": "Case 1:20-cr-00330-PAE Document 392 Filed 10/29/21 Page 5 of 8",
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    {
      "type": "printed",
      "content": "On June 23, 2021, almost twenty years after the alleged events, and 14 years after did not identify Ms. Maxwell as the perpetrator of any crime, the Government presented with a series of photographs, attached as Exhibit A. The photographic identification procedure used was the functional equivalent of a one-on-one show-up. Any identification is tainted and should therefore be suppressed by the Court.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "ARGUMENT",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "A defendant's right to due process includes the right not to be the object of suggestive police identification procedures that create \"a very substantial likelihood of irreparable misidentification.\" Simmons v. United States, 390 U.S. 377, 384 (1968); accord Neil v. Biggers, 409 U.S. 188, 198 (1972); see also Manson v. Brathwaite, 432 U.S. 98, 106 n.9, 114 (1977). This principle applies both to show-ups, see, e.g., Stovall v. Denno, 388 U.S. 293 (1967), and to photographic identifications. Simmons v. United States, 390 U.S. 377, 384 (1968).",
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      "type": "printed",
      "content": "2",
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    {
      "type": "printed",
      "content": "DOJ-OGR-00005742",
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  "entities": {
    "people": [
      "Maxwell"
    ],
    "organizations": [
      "Government",
      "Court"
    ],
    "locations": [],
    "dates": [
      "June 23, 2021",
      "10/29/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 392",
      "DOJ-OGR-00005742"
    ]
  },
  "additional_notes": "The document contains redactions, likely to protect sensitive information or witness identities."
}