{
  "document_metadata": {
    "page_number": "20",
    "document_number": "465",
    "date": "11/15/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 20 of 127\nLB1TMAX1\ndid not have an alibi and suggested that a photo lineup was unduly suggestive. 799 F.2d 593, (10th Cir. 1986). The court stated that, if disclosed, \"the defense could have cross-examined the detectives about their decision to use the photographs\" that they did as well about their failure to corroborate the other suspect's alibi.\nAnd the defense cites another Brady violation in Lindsey v. King where the Fifth Circuit found that a police report was material under Brady because it showed key witnesses to a murder had changed their story, which on cross-examination would have meant the destruction of the witness's identification and the discrediting in some degree of the police methods employed in assembling the case against the defendant. Lindsey v. King, 769 F.2d 1034, (5th Cir. 1985).\nThese two examples of focused cross-examination to impeach a witness that testified to the defendant's guilt and thereby throw the product of the government's investigation into doubt are far afield from the specifics of what the defense proposed here. In its brief, the defense seeks to affirmatively -- and I will quote from their brief -- \"call FBI case agents as witnesses\" to ask who they talked to, what documents they subpoenaed, and when. See, defense's response at 40. But as the Second Circuit explained in Saldarriaga, the government's use or non-use of certain investigative techniques does not tend to show the defendant's innocence of the charges.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00007071",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 20 of 127",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "LB1TMAX1\ndid not have an alibi and suggested that a photo lineup was unduly suggestive. 799 F.2d 593, (10th Cir. 1986). The court stated that, if disclosed, \"the defense could have cross-examined the detectives about their decision to use the photographs\" that they did as well about their failure to corroborate the other suspect's alibi.\nAnd the defense cites another Brady violation in Lindsey v. King where the Fifth Circuit found that a police report was material under Brady because it showed key witnesses to a murder had changed their story, which on cross-examination would have meant the destruction of the witness's identification and the discrediting in some degree of the police methods employed in assembling the case against the defendant. Lindsey v. King, 769 F.2d 1034, (5th Cir. 1985).\nThese two examples of focused cross-examination to impeach a witness that testified to the defendant's guilt and thereby throw the product of the government's investigation into doubt are far afield from the specifics of what the defense proposed here. In its brief, the defense seeks to affirmatively -- and I will quote from their brief -- \"call FBI case agents as witnesses\" to ask who they talked to, what documents they subpoenaed, and when. See, defense's response at 40. But as the Second Circuit explained in Saldarriaga, the government's use or non-use of certain investigative techniques does not tend to show the defendant's innocence of the charges.",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00007071",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [],
    "organizations": [
      "FBI",
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [],
    "dates": [
      "11/15/21",
      "1986",
      "1985"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 465",
      "799 F.2d 593",
      "769 F.2d 1034",
      "DOJ-OGR-00007071"
    ]
  },
  "additional_notes": "The document appears to be a court transcript or legal brief. The text is printed and there are no visible handwritten notes or stamps. The document is well-formatted and easy to read."
}