{
  "document_metadata": {
    "page_number": "82 of 93",
    "document_number": "410-1",
    "date": "11/04/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 410-1 Filed 11/04/21 Page 82 of 93\n\nParticular Investigative Techniques Not Required\n[If applicable]\nYou have heard reference, in the arguments of defense counsel in this case, to the fact that certain investigative techniques were used or not used by the Government. There is no legal requirement, however, that the Government prove its case through any particular means. While you are to carefully consider the evidence adduced by the Government, you are not to speculate as to why they used the techniques they did or why they did not use other techniques. The Government is not on trial. Law enforcement techniques are not your concern.\nYour concern is to determine whether or not, on the evidence or lack of evidence, the defendant's guilt has been proved beyond a reasonable doubt.\nAdapted from the charge of the Hon. Alison J. Nathan in United States v. Jones, 16 Cr. 553 (AJN); and in United States v. Pizarro, 17 Cr. 151 (AJN); the charge of the Hon. Kimba M. Wood in United States v. Almonte, 16 Cr. 670 (KMW); the charge of the Hon. Denise L. Cote in United States v. Purcell, 18 Cr. 081 (DLC); and the charge of the Hon. P. Kevin Castel in United States v. William Walters, 16 Cr. 338 (PKC).\n82\nDOJ-OGR-00006148",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 410-1 Filed 11/04/21 Page 82 of 93",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Particular Investigative Techniques Not Required\n[If applicable]",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "You have heard reference, in the arguments of defense counsel in this case, to the fact that certain investigative techniques were used or not used by the Government. There is no legal requirement, however, that the Government prove its case through any particular means. While you are to carefully consider the evidence adduced by the Government, you are not to speculate as to why they used the techniques they did or why they did not use other techniques. The Government is not on trial. Law enforcement techniques are not your concern.",
      "position": "middle"
    },
    {
      "type": "handwritten",
      "content": "you are to carefully consider the evidence adduced by the Government, you are not to speculate as to why they used the techniques they did or why they did not use other techniques. The Government is not on trial. Law enforcement techniques are not your concern.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Your concern is to determine whether or not, on the evidence or lack of evidence, the defendant's guilt has been proved beyond a reasonable doubt.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Adapted from the charge of the Hon. Alison J. Nathan in United States v. Jones, 16 Cr. 553 (AJN); and in United States v. Pizarro, 17 Cr. 151 (AJN); the charge of the Hon. Kimba M. Wood in United States v. Almonte, 16 Cr. 670 (KMW); the charge of the Hon. Denise L. Cote in United States v. Purcell, 18 Cr. 081 (DLC); and the charge of the Hon. P. Kevin Castel in United States v. William Walters, 16 Cr. 338 (PKC).",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "82",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00006148",
      "position": "footer"
    },
    {
      "type": "handwritten",
      "content": "Commented [CE99]: The defense maintains its position that it is entitled to challenge the thoroughness and good faith of the government's investigation. See Kyles v. Whitley, 514 U.S. 419, 445 (1995) The government is free to argue in response that its investigation was thorough and proper This instruction is argumentative and highlights the government's arguments at the expense of Ms Maxwell's",
      "position": "margin"
    },
    {
      "type": "handwritten",
      "content": "Commented [RA100R99]: GOVERNMENT RESPONSE: As the Court has concluded, the principle captured by this instruction is settled law in this circuit",
      "position": "margin"
    },
    {
      "type": "handwritten",
      "content": "Commented [CE101]: At the very least, this language should be omitted. It is repetitive and favors the government Furthermore, the Court has omitted this language from its recent instructions on this issue. See United States v. Pizarro, 17 Cr 151 (AJN)",
      "position": "margin"
    },
    {
      "type": "handwritten",
      "content": "Commented [RA102R101]: GOVERNMENT RESPONSE: The Court has already ruled that the Government's motivations and use of investigative techniques are not relevant or admissible The Second Circuit has affirmed nearly this instruction, United States v. Praddyiah, 456 F. App'x 56, 60 (2d Cir. 2012) (summary order) and held that an instruction that \"the government is not on trial\" is \"appropriate.\" United States v. Knox, 687 F. App'x 51, 54-55 (2d Cir. 2017) (summary order) This Court has also previously given this instruction. See United States v. Le, 15 Cr 38 (AJN)",
      "position": "margin"
    },
    {
      "type": "handwritten",
      "content": "Because the defense has repeatedly signaled their intent to place the Government's motivations and conduct at issue, the Government submits that a clear instruction like this is necessary",
      "position": "margin"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Kimba M. Wood",
      "Denise L. Cote",
      "P. Kevin Castel",
      "Ms Maxwell"
    ],
    "organizations": [
      "Government"
    ],
    "locations": [],
    "dates": [
      "11/04/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "410-1",
      "16 Cr. 553",
      "17 Cr. 151",
      "16 Cr. 670",
      "18 Cr. 081",
      "16 Cr. 338",
      "DOJ-OGR-00006148"
    ]
  },
  "additional_notes": "The document appears to be a court filing with annotations and comments in the margins. The main text discusses the use of investigative techniques in a trial and the relevance of the government's methods to the defendant's guilt. The annotations and comments provide additional context and insights into the case, including references to relevant case law and the positions of the defense and government."
}