{
  "document_metadata": {
    "page_number": "3",
    "document_number": "188",
    "date": "03/29/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 188 Filed 03/29/21 Page 3 of 5\nPage 3\nCount Six of the S2 Indictment adds another new charge against the defendant. In particular, Count Six alleges that the defendant participated in the sex trafficking of a minor, and aided and abetted the same, in violation of 18 U.S.C. §§ 1591 and 2. The S2 Indictment specifically identifies Minor Victim-4 as the victim of this count.\nCount Seven of the S2 Indictment is identical to Count Five of the S1 Indictment and is otherwise unchanged.\nCount Eight of the S2 Indictment is identical to Count Six of the S1 Indictment and is otherwise unchanged.\nII. Disclosures\nThe Government has already produced to the defense all material that constitutes Rule 16 discovery related to the new allegations and charges contained in the S2 Indictment. In particular, the Government has from the outset approached its Rule 16 productions in this case as though the allegations covered a broader time period through at least 2005, rather than limiting those productions to the time period alleged in the S1 Indictment (1994 to 1997). As a result, the Government has already produced to the defense all Rule 16 material relevant to the S2 Indictment of which it is aware in the Prosecution Team's possession. These Rule 16 materials included productions from the files of the Federal Bureau of Investigation (\"FBI\") Palm Beach Resident Agency (the \"FBI Florida Office\"), the FBI New York Office, and the U.S. Attorney's Office for the Southern District of New York.\nTo assist the defense in preparing for trial on the new allegations contained in the S2 Indictment, today the Government provided the defense with Minor Victim-4's month and year of birth. Additionally, in order to aid the defense in its trial preparation and review of the discovery, DOJ-OGR-00002869",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 188 Filed 03/29/21 Page 3 of 5",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Count Six of the S2 Indictment adds another new charge against the defendant. In particular, Count Six alleges that the defendant participated in the sex trafficking of a minor, and aided and abetted the same, in violation of 18 U.S.C. §§ 1591 and 2. The S2 Indictment specifically identifies Minor Victim-4 as the victim of this count.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Count Seven of the S2 Indictment is identical to Count Five of the S1 Indictment and is otherwise unchanged.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Count Eight of the S2 Indictment is identical to Count Six of the S1 Indictment and is otherwise unchanged.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "II. Disclosures",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The Government has already produced to the defense all material that constitutes Rule 16 discovery related to the new allegations and charges contained in the S2 Indictment. In particular, the Government has from the outset approached its Rule 16 productions in this case as though the allegations covered a broader time period through at least 2005, rather than limiting those productions to the time period alleged in the S1 Indictment (1994 to 1997). As a result, the Government has already produced to the defense all Rule 16 material relevant to the S2 Indictment of which it is aware in the Prosecution Team's possession. These Rule 16 materials included productions from the files of the Federal Bureau of Investigation (\"FBI\") Palm Beach Resident Agency (the \"FBI Florida Office\"), the FBI New York Office, and the U.S. Attorney's Office for the Southern District of New York.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "To assist the defense in preparing for trial on the new allegations contained in the S2 Indictment, today the Government provided the defense with Minor Victim-4's month and year of birth. Additionally, in order to aid the defense in its trial preparation and review of the discovery,",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00002869",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Minor Victim-4"
    ],
    "organizations": [
      "FBI",
      "U.S. Attorney's Office"
    ],
    "locations": [
      "New York",
      "Florida",
      "Palm Beach"
    ],
    "dates": [
      "03/29/21",
      "1994",
      "1997",
      "2005"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 188",
      "DOJ-OGR-00002869"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is printed and there are no visible stamps or handwritten notes. The document is page 3 of 5."
}