{
  "document_metadata": {
    "page_number": "212",
    "document_number": "204",
    "date": "04/16/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 212 of 239 to review the statements of testifying witnesses. The Government remains open to engaging in good faith discussions with the defense to mutually agree on a schedule for reciprocal pretrial disclosures.64 Accordingly, the motion for a witness list and early production of Jencks Act material should be denied. C. The Defendant's Additional Requests for Disclosure Should Be Denied The defendant also makes a variety of motions seeking disclosures to which she is not entitled, all of which should be denied. First, the defendant requests , which the defense attached to their motion as Exhibit B. (Def. Mot. 10 at 7-8). The defense assumes that because , thereby, according to the defense, rendering any record of those interviews exculpatory. But that defense theory rests on a faulty premise. The Government has reviewed the document memorializing and confirmed that it inculpates the defendant and contains nothing exculpatory. The Government has also reviewed and confirmed that it also inculpates the defendant. The Government has, however, identified a single line in that could arguably be considered helpful to the defense.65 With the possible exception of that one line, there is nothing exculpatory contained in the defense. 64 The Government has requested reciprocal discovery from the defendant and, to date, she has produced nothing. 65 In particular. 185 DOJ-OGR-00003146",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 212 of 239",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "to review the statements of testifying witnesses. The Government remains open to engaging in good faith discussions with the defense to mutually agree on a schedule for reciprocal pretrial disclosures.64 Accordingly, the motion for a witness list and early production of Jencks Act material should be denied.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "C. The Defendant's Additional Requests for Disclosure Should Be Denied",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The defendant also makes a variety of motions seeking disclosures to which she is not entitled, all of which should be denied.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "First, the defendant requests , which the defense attached to their motion as Exhibit B. (Def. Mot. 10 at 7-8). The defense assumes that because , thereby, according to the defense, rendering any record of those interviews exculpatory. But that defense theory rests on a faulty premise. The Government has reviewed the document memorializing and confirmed that it inculpates the defendant and contains nothing exculpatory. The Government has also reviewed and confirmed that it also inculpates the defendant. The Government has, however, identified a single line in that could arguably be considered helpful to the defense.65 With the possible exception of that one line, there is nothing exculpatory contained in the defense.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "64 The Government has requested reciprocal discovery from the defendant and, to date, she has produced nothing.",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "65 In particular.",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "185",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00003146",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [],
    "organizations": [
      "Government",
      "DOJ"
    ],
    "locations": [],
    "dates": [
      "04/16/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 204",
      "DOJ-OGR-00003146"
    ]
  },
  "additional_notes": "The document contains redactions, likely to protect sensitive information."
}