{
  "document_metadata": {
    "page_number": "20 of 23",
    "document_number": "148",
    "date": "02/04/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 148 Filed 02/04/21 Page 20 of 23\n\nCourt may order the disclosure when a balancing of the defendant's need for disclosure and the government's need for concealment indicates that such an order would be in the interests of justice. See Cannone, 528 F.2d at 300-02. Trial courts generally exercise discretion to order such disclosure upon a finding that a defendant's request is material to the preparation of the case and is otherwise reasonable. See id. at 300-01. Courts assess the materiality and reasonableness of the request through the application of a six-factor test set forth in United States v. Turkish, 458 F. Supp. 874 (S.D.N.Y. 1978):\n\n1. Did the offense alleged in the indictment involve a crime of violence?\n2. Have the defendants been arrested or convicted for crimes involving violence?\n3. Will the evidence in the case largely consist of testimony relating to documents (which by their nature are not easily altered)?\n4. Is there a realistic possibility that supplying the witnesses' names prior to trial will increase the likelihood that the prosecution's witnesses will not appear at trial, or will be unwilling to testify at trial?\n5. Does the indictment allege offenses occurring over an extended period of time, making preparation of the defendants' defense complex and difficult?\n6. Do the defendants have limited funds with which to investigate and prepare their defense?\n\nId. at 881.\n\nHere, the application of the Turkish factors favors early disclosure of the identities of the government's witnesses. The indictment does not allege crimes of violence, Ms. Maxwell has no criminal history, and the government has conceded that she is not a danger to the community.\n\nThe age of the charged offenses and the complications imposed by a global pandemic makes investigation and preparation of this case complex and difficult. Disclosure of the government's witness list is material to the preparation of the defense and reasonable in light of the circumstances surrounding this case.\n\n16\nDOJ-OGR-00002713",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 148 Filed 02/04/21 Page 20 of 23",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Court may order the disclosure when a balancing of the defendant's need for disclosure and the government's need for concealment indicates that such an order would be in the interests of justice. See Cannone, 528 F.2d at 300-02. Trial courts generally exercise discretion to order such disclosure upon a finding that a defendant's request is material to the preparation of the case and is otherwise reasonable. See id. at 300-01. Courts assess the materiality and reasonableness of the request through the application of a six-factor test set forth in United States v. Turkish, 458 F. Supp. 874 (S.D.N.Y. 1978):",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "1. Did the offense alleged in the indictment involve a crime of violence?\n2. Have the defendants been arrested or convicted for crimes involving violence?\n3. Will the evidence in the case largely consist of testimony relating to documents (which by their nature are not easily altered)?\n4. Is there a realistic possibility that supplying the witnesses' names prior to trial will increase the likelihood that the prosecution's witnesses will not appear at trial, or will be unwilling to testify at trial?\n5. Does the indictment allege offenses occurring over an extended period of time, making preparation of the defendants' defense complex and difficult?\n6. Do the defendants have limited funds with which to investigate and prepare their defense?",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Id. at 881.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Here, the application of the Turkish factors favors early disclosure of the identities of the government's witnesses. The indictment does not allege crimes of violence, Ms. Maxwell has no criminal history, and the government has conceded that she is not a danger to the community.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The age of the charged offenses and the complications imposed by a global pandemic makes investigation and preparation of this case complex and difficult. Disclosure of the government's witness list is material to the preparation of the defense and reasonable in light of the circumstances surrounding this case.",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "16",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00002713",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Maxwell"
    ],
    "organizations": [],
    "locations": [
      "S.D.N.Y."
    ],
    "dates": [
      "02/04/21",
      "1978"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "Document 148",
      "DOJ-OGR-00002713"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is well-formatted and easy to read. There are no visible redactions or damage to the document."
}