{
  "document_metadata": {
    "page_number": "220 of 239",
    "document_number": "204",
    "date": "04/16/21",
    "document_type": "court document",
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    "has_stamps": false
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  "full_text": "Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 220 of 239\n\nFinally, the defendant requests early disclosure of Rule 404(b) material that the Government may seek to introduce at trial. (Def. Mot. 10 at 17). As is customary in this district, the Government will provide notice to the defense of its intent to use any such evidence at least 45 days in advance of trial, which will leave sufficient time for the defense may file any motions in limine to be considered at the final pretrial conference. See Thompson, 2013 WL 6246489 at *9 (“The Government has represented that it will disclose the substance of [the 404(b) evidence it intends to introduce at trial] . . . in a timely fashion in order to permit the defendants the opportunity to challenge admission and to permit the Court to make an appropriate finding. This is all that Rule 404(b) requires.” (alterations in original) (internal citation omitted)); United States v. Tranquillo, 606 F. Supp. 2d 370, 383 (S.D.N.Y. 2009) (“The Government has indicated that it will make the required disclosure two weeks prior to trial, a practice that typically comports with Rule 404(b)); United States v. Fennell, 496 F. Supp. 2d 279, 284 (S.D.N.Y. 2007) (“The government has in good faith noted its obligations under Rule 404(b), and indicated that it intends to provide notice of the 404(b) evidence it intends to introduce two weeks before the beginning of trial. There is therefore no need to issue the order Defendant seeks.”). Accordingly, this motion should be denied.\n\nXI. The Use of a Grand Jury Siting in White Plains Was Entirely Proper\n\nOn June 29, 2020, amidst a global pandemic that suspended grand juries across the country, the Government sought and obtained an indictment from a grand jury of the Southern District of New York (the “Southern District” or “SDNY”) sitting in White Plains. The defendant now challenges the pool from which that grand jury was drawn, alleging that it does not reflect a “fair-cross section of the community,” and moves to dismiss the Indictment under the Sixth Amendment. (Def. Mot. 9 at 1). As set forth below, the defendant’s arguments rely on faulty\n\n193\n\nDOJ-OGR-00003154",
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      "content": "Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 220 of 239",
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      "type": "printed",
      "content": "Finally, the defendant requests early disclosure of Rule 404(b) material that the Government may seek to introduce at trial. (Def. Mot. 10 at 17). As is customary in this district, the Government will provide notice to the defense of its intent to use any such evidence at least 45 days in advance of trial, which will leave sufficient time for the defense may file any motions in limine to be considered at the final pretrial conference. See Thompson, 2013 WL 6246489 at *9 (“The Government has represented that it will disclose the substance of [the 404(b) evidence it intends to introduce at trial] . . . in a timely fashion in order to permit the defendants the opportunity to challenge admission and to permit the Court to make an appropriate finding. This is all that Rule 404(b) requires.” (alterations in original) (internal citation omitted)); United States v. Tranquillo, 606 F. Supp. 2d 370, 383 (S.D.N.Y. 2009) (“The Government has indicated that it will make the required disclosure two weeks prior to trial, a practice that typically comports with Rule 404(b)); United States v. Fennell, 496 F. Supp. 2d 279, 284 (S.D.N.Y. 2007) (“The government has in good faith noted its obligations under Rule 404(b), and indicated that it intends to provide notice of the 404(b) evidence it intends to introduce two weeks before the beginning of trial. There is therefore no need to issue the order Defendant seeks.”). Accordingly, this motion should be denied.",
      "position": "top"
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    {
      "type": "printed",
      "content": "XI. The Use of a Grand Jury Siting in White Plains Was Entirely Proper",
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    {
      "type": "printed",
      "content": "On June 29, 2020, amidst a global pandemic that suspended grand juries across the country, the Government sought and obtained an indictment from a grand jury of the Southern District of New York (the “Southern District” or “SDNY”) sitting in White Plains. The defendant now challenges the pool from which that grand jury was drawn, alleging that it does not reflect a “fair-cross section of the community,” and moves to dismiss the Indictment under the Sixth Amendment. (Def. Mot. 9 at 1). As set forth below, the defendant’s arguments rely on faulty",
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      "content": "193",
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      "type": "printed",
      "content": "DOJ-OGR-00003154",
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  "entities": {
    "people": [],
    "organizations": [
      "Government",
      "Court",
      "Southern District of New York",
      "SDNY"
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    "locations": [
      "White Plains",
      "New York"
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    "dates": [
      "04/16/21",
      "June 29, 2020"
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    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 204",
      "DOJ-OGR-00003154"
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  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is mostly printed, with no visible handwriting or stamps. The document is well-formatted and legible."
}