{
  "document_metadata": {
    "page_number": "27",
    "document_number": "383",
    "date": "10/29/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 383 Filed 10/29/21 Page 27 of 40\n\nparticular set of circumstances, and none address evidentiary rulings. Instead, these cases concern Brady errors involving the withholding of exculpatory information, such as a statement in which a witness at trial stated that he \"did not see the perpetrator's face,\" Lindsey v. King, 769 F.2d 1034, 1036 (5th Cir. 1985), or evidence pointing toward an alternative perpetrator, Bowen v. Maynard, 799 F.2d 593, 612 (10th Cir. 1986). See also Kyles, 514 U.S. at 445-46 (confidential informant \"essential to [the Government's] investigation\" made statements \"replete with inconsistencies\").\n\nIn addition to the obvious exculpatory value of this information, the courts explained that it would be used to \"attack[] the reliability of the investigation.\" Kyles, 514 U.S. at 446.\n\nThe defense would rest a pile of irrelevant evidence on this slender reed. In their view, from the principle that the defense can attack the \"thoroughness\" of an investigation, they may elicit any information aimed at explaining—and attacking—the decisionmaking of the agents and prosecutors involved in a case. Kyles, the case chiefly cited by the defense, is about whether the \"prosecution improperly withheld evidence that, had it been disclosed, would have 'raised opportunities to attack the thoroughness and even the good faith of the investigation.'\" Kyles provides no guidance about what evidence must be admitted at trial or what lines of questioning must be permitted to ensure a meaningful opportunity to cross-examine adverse witnesses,\" Watson v. Greene, 640 F.3d 501, 512 n.11 (2d Cir. 2011) (emphasis added, alteration in original, citation omitted), nor do the other cases.\n\nEven if the cases cited by the defense spoke directly to this context, and not the limits of Brady material, they still would not reach so far. For instance, in Bowen, the Tenth Circuit found that if the defense had been provided information about the alternative perpetrator, they could have",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 383 Filed 10/29/21 Page 27 of 40",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "particular set of circumstances, and none address evidentiary rulings. Instead, these cases concern Brady errors involving the withholding of exculpatory information, such as a statement in which a witness at trial stated that he \"did not see the perpetrator's face,\" Lindsey v. King, 769 F.2d 1034, 1036 (5th Cir. 1985), or evidence pointing toward an alternative perpetrator, Bowen v. Maynard, 799 F.2d 593, 612 (10th Cir. 1986). See also Kyles, 514 U.S. at 445-46 (confidential informant \"essential to [the Government's] investigation\" made statements \"replete with inconsistencies\").",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "In addition to the obvious exculpatory value of this information, the courts explained that it would be used to \"attack[] the reliability of the investigation.\" Kyles, 514 U.S. at 446.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "The defense would rest a pile of irrelevant evidence on this slender reed. In their view, from the principle that the defense can attack the \"thoroughness\" of an investigation, they may elicit any information aimed at explaining—and attacking—the decisionmaking of the agents and prosecutors involved in a case. Kyles, the case chiefly cited by the defense, is about whether the \"prosecution improperly withheld evidence that, had it been disclosed, would have 'raised opportunities to attack the thoroughness and even the good faith of the investigation.'\" Kyles provides no guidance about what evidence must be admitted at trial or what lines of questioning must be permitted to ensure a meaningful opportunity to cross-examine adverse witnesses,\" Watson v. Greene, 640 F.3d 501, 512 n.11 (2d Cir. 2011) (emphasis added, alteration in original, citation omitted), nor do the other cases.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Even if the cases cited by the defense spoke directly to this context, and not the limits of Brady material, they still would not reach so far. For instance, in Bowen, the Tenth Circuit found that if the defense had been provided information about the alternative perpetrator, they could have",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "26",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00005581",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "King",
      "Maynard",
      "Greene"
    ],
    "organizations": [],
    "locations": [],
    "dates": [
      "10/29/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 383",
      "769 F.2d 1034",
      "799 F.2d 593",
      "514 U.S. at 445-46",
      "640 F.3d 501",
      "DOJ-OGR-00005581"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case, discussing Brady errors and the withholding of exculpatory information. The text is printed and there are no visible stamps or handwritten notes."
}