{
  "document_metadata": {
    "page_number": "2",
    "document_number": "227",
    "date": "04/21/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 227 Filed 04/21/21 Page 2 of 3\nPage 2\nin question include, among other things, depositions of potential witnesses.1 If the defense were to put these documents at issue at trial, during either the defense case or the cross-examination of witnesses, the Government reserves its right to use relevant materials from this set for any purpose permissible under the Rules of Evidence. Likewise, the Government has no objection to the defense using these materials at trial for any permissible purpose under the Rules of Evidence, including to cross-examine trial witnesses.\nMoreover, the Government notes that, even if these materials were suppressed - which the Government submits is inappropriate here - the Government would nonetheless have the right to offer these materials under certain circumstances. For example, it is well established that a criminal defendant who testifies in her own defense may be impeached with materials that would otherwise be subject to suppression. United States v. Trzaska, 111 F.3d 1019, 1026 (2d Cir. 1997) (“The Supreme Court has held that illegally acquired evidence may be used to impeach defendants who testify in their own defense.”) (citing Walder v. United States, 347 U.S. 62, 64-66 (1954)). As the Supreme Court has explained, the exclusionary rule must be balanced with the truth-seeking functions of a trial:\nIt is one thing to say that the Government cannot make an affirmative use of evidence unlawfully obtained. It is quite another to say that the defendant can turn the illegal method by which evidence in the Government’s possession was obtained to his own advantage, and provide himself with a shield against contradiction of his untruths. Such an extension of the Weeks doctrine would be a perversion of the Fourth Amendment.\n1 The Government further notes that many of the materials in the file in question are duplicates of materials the Government has obtained through other sources. For example, the file contains materials that appear to have been obtained from third parties and law enforcement agencies. At trial, the Government is likely to offer documents it has obtained during its investigation through other sources, even though those materials happen to be contained in duplicate in the file in question.\nDOJ-OGR-00003919",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 227 Filed 04/21/21 Page 2 of 3",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Page 2",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "in question include, among other things, depositions of potential witnesses.1 If the defense were to put these documents at issue at trial, during either the defense case or the cross-examination of witnesses, the Government reserves its right to use relevant materials from this set for any purpose permissible under the Rules of Evidence. Likewise, the Government has no objection to the defense using these materials at trial for any permissible purpose under the Rules of Evidence, including to cross-examine trial witnesses.",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "Moreover, the Government notes that, even if these materials were suppressed - which the Government submits is inappropriate here - the Government would nonetheless have the right to offer these materials under certain circumstances. For example, it is well established that a criminal defendant who testifies in her own defense may be impeached with materials that would otherwise be subject to suppression. United States v. Trzaska, 111 F.3d 1019, 1026 (2d Cir. 1997) (“The Supreme Court has held that illegally acquired evidence may be used to impeach defendants who testify in their own defense.”) (citing Walder v. United States, 347 U.S. 62, 64-66 (1954)). As the Supreme Court has explained, the exclusionary rule must be balanced with the truth-seeking functions of a trial:",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "It is one thing to say that the Government cannot make an affirmative use of evidence unlawfully obtained. It is quite another to say that the defendant can turn the illegal method by which evidence in the Government’s possession was obtained to his own advantage, and provide himself with a shield against contradiction of his untruths. Such an extension of the Weeks doctrine would be a perversion of the Fourth Amendment.",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "1 The Government further notes that many of the materials in the file in question are duplicates of materials the Government has obtained through other sources. For example, the file contains materials that appear to have been obtained from third parties and law enforcement agencies. At trial, the Government is likely to offer documents it has obtained during its investigation through other sources, even though those materials happen to be contained in duplicate in the file in question.",
      "position": "footnote"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00003919",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [],
    "organizations": [
      "Government",
      "Supreme Court"
    ],
    "locations": [],
    "dates": [
      "04/21/21",
      "1954"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "227",
      "DOJ-OGR-00003919"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is well-formatted and printed, with no visible handwriting or stamps. The content discusses the use of evidence in a trial and references several legal precedents."
}