{
  "document_metadata": {
    "page_number": "2",
    "document_number": "411",
    "date": "11/04/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 411 Filed 11/04/21 Page 2 of 3\nPage 2\nunder Rule 404(b) or as direct evidence of the sex trafficking counts; (5) reviewing 400 juror questionnaires, conferring with the defense, and filing lists of for-cause strikes with the Court; (6) responding to the defendant's fourth bail motion (see Dkt. No. 408); and (7) conferring with the MDC regarding the defendant's legal mail and transportation to the courthouse.² By November 10, the Government will also (8) respond to defense objections to the admissibility of co-conspirator statements, including a discussion of statements that postulate the charged period of the conspiracy; (9) propose procedures for the use of pseudonyms following conferral with defense counsel; and (10) provide a letter regarding the admissibility of Government Exhibit 52. This is in addition to the ordinary press of preparing for trial, which in this case involves, among other things, extensive travel to meet with victim witnesses.\nThe Government is grateful for the care and attention that the Court has devoted to this case and the speed and efficiency with which the Court has resolved pretrial matters. In the Government's view, however, the foregoing confluence of deadlines seriously taxes the Government's ability to provide the Court with the thorough, careful briefing and advocacy that the Court rightly expects. It is not practicable to further require the Government to brief in six days the admissibility of testimony from several defense expert witnesses, particularly when (a) the defense had six months to brief the admissibility of a single expert witness; (b) the defense has clearly known the identity of these eight experts for some time; and (c) there is additional time between now and the start of trial in which to brief and resolve the issues surrounding these experts.\nAccordingly, the Government respectfully requests that the Court set a deadline for any\n² In addition, on November 3, 2021, the Government provided the Court with the joint request to charge and verdict form, for which the Government received full comments from the defense late last night.\nDOJ-OGR-00006163",
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      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 411 Filed 11/04/21 Page 2 of 3",
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    },
    {
      "type": "printed",
      "content": "Page 2",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "under Rule 404(b) or as direct evidence of the sex trafficking counts; (5) reviewing 400 juror questionnaires, conferring with the defense, and filing lists of for-cause strikes with the Court; (6) responding to the defendant's fourth bail motion (see Dkt. No. 408); and (7) conferring with the MDC regarding the defendant's legal mail and transportation to the courthouse.² By November 10, the Government will also (8) respond to defense objections to the admissibility of co-conspirator statements, including a discussion of statements that postulate the charged period of the conspiracy; (9) propose procedures for the use of pseudonyms following conferral with defense counsel; and (10) provide a letter regarding the admissibility of Government Exhibit 52. This is in addition to the ordinary press of preparing for trial, which in this case involves, among other things, extensive travel to meet with victim witnesses.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The Government is grateful for the care and attention that the Court has devoted to this case and the speed and efficiency with which the Court has resolved pretrial matters. In the Government's view, however, the foregoing confluence of deadlines seriously taxes the Government's ability to provide the Court with the thorough, careful briefing and advocacy that the Court rightly expects. It is not practicable to further require the Government to brief in six days the admissibility of testimony from several defense expert witnesses, particularly when (a) the defense had six months to brief the admissibility of a single expert witness; (b) the defense has clearly known the identity of these eight experts for some time; and (c) there is additional time between now and the start of trial in which to brief and resolve the issues surrounding these experts.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Accordingly, the Government respectfully requests that the Court set a deadline for any",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "² In addition, on November 3, 2021, the Government provided the Court with the joint request to charge and verdict form, for which the Government received full comments from the defense late last night.",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00006163",
      "position": "footer"
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  ],
  "entities": {
    "people": [],
    "organizations": [
      "Government",
      "Court",
      "MDC"
    ],
    "locations": [
      "courthouse"
    ],
    "dates": [
      "November 10",
      "November 3, 2021"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 411",
      "Dkt. No. 408",
      "Government Exhibit 52",
      "DOJ-OGR-00006163"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is well-formatted and clear, with no visible redactions or damage."
}