{
  "document_metadata": {
    "page_number": "13",
    "document_number": "93",
    "date": "12/10/20",
    "document_type": "court transcript",
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    "has_stamps": false
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  "full_text": "Case 1:20-cr-00330-AJN Document 93 Filed 12/10/20 Page 13 of 91 13\n\n1 the entry of that protective order, as I noted, your Honor, the\n2 government is prepared to make a substantial production of\n3 discovery.\n4 Your Honor, in advance of the conference, the\n5 government and defense counsel proposed a joint schedule for\n6 discovery, motion practice, and a proposed trial date, in\n7 particular, the date selected in that schedule with an eye\n8 towards assuring that there was sufficient time for the\n9 government to do a careful and exhaustive and thorough review\n10 of all of the materials that I just referenced to make sure\n11 that the government is complying with its discovery obligations\n12 in this case, which we take very seriously. We expect that the\n13 bulk of the relevant materials will be produced in short order,\n14 primarily by the end of this summer, with additional materials\n15 to follow primarily in a category I mentioned before, your\n16 Honor, of electronically stored information, which is subject\n17 to an ongoing privilege review which we discussed and\n18 communicated with defense counsel about. We have proposed a\n19 scheduling order again to be very thorough in our review of\n20 discovery and in files in various places where they may be\n21 located and we are taking an expansive and thoughtful approach\n22 to our obligations in this case, your Honor.\n23 THE COURT: Let me just follow up specifically, since\n24 you have referenced prior investigative files, to the extent we\n25 have seen in other matters issues with complete disclosure of\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00001890",
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      "content": "Case 1:20-cr-00330-AJN Document 93 Filed 12/10/20 Page 13 of 91 13",
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      "type": "printed",
      "content": "1 the entry of that protective order, as I noted, your Honor, the\ngovernment is prepared to make a substantial production of\ndiscovery.\n4 Your Honor, in advance of the conference, the\ngovernment and defense counsel proposed a joint schedule for\ndiscovery, motion practice, and a proposed trial date, in\nparticular, the date selected in that schedule with an eye\ntowards assuring that there was sufficient time for the\ngovernment to do a careful and exhaustive and thorough review\nof all of the materials that I just referenced to make sure\nthat the government is complying with its discovery obligations\nin this case, which we take very seriously. We expect that the\nbulk of the relevant materials will be produced in short order,\nprimarily by the end of this summer, with additional materials\nto follow primarily in a category I mentioned before, your\nHonor, of electronically stored information, which is subject\nto an ongoing privilege review which we discussed and\ncommunicated with defense counsel about. We have proposed a\nscheduling order again to be very thorough in our review of\ndiscovery and in files in various places where they may be\nlocated and we are taking an expansive and thoughtful approach\nto our obligations in this case, your Honor.",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "23 THE COURT: Let me just follow up specifically, since\nyou have referenced prior investigative files, to the extent we\nhave seen in other matters issues with complete disclosure of",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00001890",
      "position": "footer"
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  "entities": {
    "people": [],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [],
    "dates": [
      "12/10/20"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "93",
      "DOJ-OGR-00001890"
    ]
  },
  "additional_notes": "The document appears to be a court transcript with a clear and legible format. There are no visible redactions or damage."
}