{
  "document_metadata": {
    "page_number": "231",
    "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 231 of 239\n\nSouthern District, cases are commonly transferred from one courthouse to another, including cases that are indicted in White Plains but tried in Manhattan. See Section XI.A.1, supra (collecting examples). That is entirely consistent not just with the foregoing authority, but also with the Southern District's Local Rules for the Division of Business. See SDNY Business Division Rules 18, 19. Criminal cases are also sometimes transferred to other Districts for trial. See Fed. R. Crim. P. 21. Under the defendant's approach, it would be impossible for prosecutors to determine ex ante that that they were seeking an indictment from a grand jury drawn from a representative cross-section of the relevant community, because they would not yet know with certainty in which community the case will be tried.\n\nThe defendant's argument therefore boils down to an unfounded complaint that it is \"a deviation from the established practice\" to seek an indictment in a courthouse other than the one in which the case will likely be tried. (Def. Mot. 9 at 2). This argument is inconsistent with the foregoing law that the defendant has no right to jurors drawn from any particular geographic area within the district. See also Rosencrans v. United States, 165 U.S. 257, 260-63 (1897) (finding no error in grand jury returning indictment in a division different from the division in which the trial proceeded). It also finds no succor in the SDNY Business Division Rules, which vest no rights in any parties and, in any event, contemplate that judges may reassign cases from one courthouse to another. And it falls exceedingly flat on the facts of this case. The Government did not forum shop to achieve some perceived advantage. Rather, it sought a timely indictment from a grand jury in White Plains because it was the only grand jury with a quorum sitting in the Southern District on that date (a relatively rare situation created by an unprecedented public health crisis).\n\n204\nDOJ-OGR-00003165",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 231 of 239",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Southern District, cases are commonly transferred from one courthouse to another, including cases that are indicted in White Plains but tried in Manhattan. See Section XI.A.1, supra (collecting examples). That is entirely consistent not just with the foregoing authority, but also with the Southern District's Local Rules for the Division of Business. See SDNY Business Division Rules 18, 19. Criminal cases are also sometimes transferred to other Districts for trial. See Fed. R. Crim. P. 21. Under the defendant's approach, it would be impossible for prosecutors to determine ex ante that that they were seeking an indictment from a grand jury drawn from a representative cross-section of the relevant community, because they would not yet know with certainty in which community the case will be tried.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The defendant's argument therefore boils down to an unfounded complaint that it is \"a deviation from the established practice\" to seek an indictment in a courthouse other than the one in which the case will likely be tried. (Def. Mot. 9 at 2). This argument is inconsistent with the foregoing law that the defendant has no right to jurors drawn from any particular geographic area within the district. See also Rosencrans v. United States, 165 U.S. 257, 260-63 (1897) (finding no error in grand jury returning indictment in a division different from the division in which the trial proceeded). It also finds no succor in the SDNY Business Division Rules, which vest no rights in any parties and, in any event, contemplate that judges may reassign cases from one courthouse to another. And it falls exceedingly flat on the facts of this case. The Government did not forum shop to achieve some perceived advantage. Rather, it sought a timely indictment from a grand jury in White Plains because it was the only grand jury with a quorum sitting in the Southern District on that date (a relatively rare situation created by an unprecedented public health crisis).",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "204",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00003165",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [],
    "organizations": [
      "SDNY"
    ],
    "locations": [
      "White Plains",
      "Manhattan",
      "Southern District"
    ],
    "dates": [
      "04/16/21",
      "1897"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 204",
      "DOJ-OGR-00003165"
    ]
  },
  "additional_notes": "The document appears to be a court filing with a clear and legible text. There are no visible redactions or damage."
}