{
  "document_metadata": {
    "page_number": "3",
    "document_number": "487",
    "date": "11/22/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 487 Filed 11/22/21 Page 3 of 8\nPage 3\nVictims];\" (3) \"[a]ny and all\" material \"submitted by each [Minor Victim]\" to the EVCP; and (4) \"communications\" between the EVCP and the Minor Victims or their counsel. (Def. Mot. Attachment A). The subpoena should be quashed as to each of these categories.3\nA. Payment Records\nThe first category—copies of payments made to the Minor Victims—concerns information already in the defendant's possession. Indeed, the defendant's motion cites the amounts received by the Minor Victims, which is reflected in their 3500 material (Def. Mot. at 3), and the Government expects the Minor Victims to testify to those amounts at trial.\nAccordingly, this information is \"otherwise procurable.\" United States v. Pena, No. 15 Cr. 551 (AJN), 2016 WL 8735699, at *2 (S.D.N.Y. Feb. 12, 2016). The subpoena should therefore be quashed. At most, the Court should order production of that information to the Court so that it may be provided to the defense in the unlikely event that the Minor Victims testify inconsistently with their prior statements at trial.\nB. Claim Release Forms\nThe defendant makes no argument for the relevance of the release forms executed by the Minor Victims, and none is apparent to the Government. The Court should therefore quash the subpoena insofar as it calls for that category of information, at least until the defendant explains what relevant and admissible evidence is contained in the release forms.\n3 The Government has standing to challenge the subpoena because it targets information about anticipated Government witnesses, \"based on the Government's 'interest in preventing any undue lengthening of the trial, any undue harassment of the witness and [her] family, and any prejudicial over-emphasis on the witness's credibility.'\" United States v. Ray, 337 F.R.D. 561, 571 (S.D.N.Y. Nov. 25, 2020) (quoting United States v. Giampa, No. 92 Cr. 437 (PKL), 1992 WL 296440, at *1 (S.D.N.Y. Oct. 7, 1992)). The Government has provided notice of this subpoena to the Minor Victims and is informed that at least two victims expect to file submissions regarding the subpoena.\nDOJ-OGR-00007395",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 487 Filed 11/22/21 Page 3 of 8",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Page 3",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Victims];\" (3) \"[a]ny and all\" material \"submitted by each [Minor Victim]\" to the EVCP; and (4) \"communications\" between the EVCP and the Minor Victims or their counsel. (Def. Mot. Attachment A). The subpoena should be quashed as to each of these categories.3",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "A. Payment Records",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "The first category—copies of payments made to the Minor Victims—concerns information already in the defendant's possession. Indeed, the defendant's motion cites the amounts received by the Minor Victims, which is reflected in their 3500 material (Def. Mot. at 3), and the Government expects the Minor Victims to testify to those amounts at trial.",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "Accordingly, this information is \"otherwise procurable.\" United States v. Pena, No. 15 Cr. 551 (AJN), 2016 WL 8735699, at *2 (S.D.N.Y. Feb. 12, 2016). The subpoena should therefore be quashed. At most, the Court should order production of that information to the Court so that it may be provided to the defense in the unlikely event that the Minor Victims testify inconsistently with their prior statements at trial.",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "B. Claim Release Forms",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "The defendant makes no argument for the relevance of the release forms executed by the Minor Victims, and none is apparent to the Government. The Court should therefore quash the subpoena insofar as it calls for that category of information, at least until the defendant explains what relevant and admissible evidence is contained in the release forms.",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "3 The Government has standing to challenge the subpoena because it targets information about anticipated Government witnesses, \"based on the Government's 'interest in preventing any undue lengthening of the trial, any undue harassment of the witness and [her] family, and any prejudicial over-emphasis on the witness's credibility.'\" United States v. Ray, 337 F.R.D. 561, 571 (S.D.N.Y. Nov. 25, 2020) (quoting United States v. Giampa, No. 92 Cr. 437 (PKL), 1992 WL 296440, at *1 (S.D.N.Y. Oct. 7, 1992)). The Government has provided notice of this subpoena to the Minor Victims and is informed that at least two victims expect to file submissions regarding the subpoena.",
      "position": "footnote"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00007395",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [],
    "organizations": [
      "EVCP",
      "Government",
      "Court"
    ],
    "locations": [
      "S.D.N.Y."
    ],
    "dates": [
      "11/22/21",
      "Feb. 12, 2016",
      "Nov. 25, 2020",
      "Oct. 7, 1992"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 487",
      "15 Cr. 551 (AJN)",
      "92 Cr. 437 (PKL)",
      "DOJ-OGR-00007395"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is well-formatted and legible. There are no visible redactions or damages."
}