{
  "document_metadata": {
    "page_number": "4",
    "document_number": "351",
    "date": "10/15/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 351 Filed 10/15/21 Page 4 of 4\nPage 4\nof them, there may be a need for multiple such hearings. The Court must then adjudicate the motion before trial starts or during trial. There is no reason to impose the defense's cramped schedule on the Court or the parties, particularly where the motion concerns such sensitive issues.\nFor these reasons, the Government respectfully submits that the Court should maintain the October 18, 2021 in limine deadline as the deadline for the defense to file a motion under Rule 412, or order that any Rule 412 motion be made, at the latest, by October 25, 2021.\nRespectfully submitted,\nDAMIAN WILLIAMS\nUnited States Attorney\nBy: s/\nAlison Moe\nLara Pomerantz\nAndrew Rohrbach\nAssistant United States Attorneys\nSouthern District of New York\nCc: Defense counsel (By ECF)\nDOJ-OGR-00005240",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 351 Filed 10/15/21 Page 4 of 4",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Page 4",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "of them, there may be a need for multiple such hearings. The Court must then adjudicate the motion before trial starts or during trial. There is no reason to impose the defense's cramped schedule on the Court or the parties, particularly where the motion concerns such sensitive issues.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "For these reasons, the Government respectfully submits that the Court should maintain the October 18, 2021 in limine deadline as the deadline for the defense to file a motion under Rule 412, or order that any Rule 412 motion be made, at the latest, by October 25, 2021.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Respectfully submitted,",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "DAMIAN WILLIAMS\nUnited States Attorney",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "By: s/\nAlison Moe\nLara Pomerantz\nAndrew Rohrbach\nAssistant United States Attorneys\nSouthern District of New York",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Cc: Defense counsel (By ECF)",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00005240",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "DAMIAN WILLIAMS",
      "Alison Moe",
      "Lara Pomerantz",
      "Andrew Rohrbach"
    ],
    "organizations": [
      "United States Attorney",
      "Southern District of New York"
    ],
    "locations": [
      "New York"
    ],
    "dates": [
      "10/15/21",
      "October 18, 2021",
      "October 25, 2021"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "351",
      "DOJ-OGR-00005240"
    ]
  },
  "additional_notes": "The document appears to be a court filing with a clear and legible format. There are no visible redactions or damage."
}