{
  "document_metadata": {
    "page_number": "208",
    "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 208 of 239 and the Government has provided the defense with the birth month and year of each minor victim.62 In other words, as the Government has previously indicated, the discovery provides the defendant with more than sufficient information about the three minor victims to permit her to prepare for trial. The discovery also provides the defense the ability to identify specific private plane flights that are relevant to the Indictment. Any remaining detail regarding the specifics of abuse, particular interactions, and additional trips will come from witness testimony. As is to be expected when describing events more than two decades in the past, that testimony will provide approximate time periods when events occurred, rather than specific dates. Given the information the defendant already has from the discovery, the Indictment, and the Government's court filings (including this memorandum), any additional detail would essentially serve as early Jencks Act production, allowing the defendant to tailor any testimony to the Government's case. The discovery gives the defense ample information to assist in its investigation, and given the defense's 62 In this memorandum, the Government has also clarified that Minor Victim-3 was 17 years old at the time of the events described in the Indictment involving her. See Section VIII, supra. 181 DOJ-OGR-00003142",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 208 of 239",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "and the Government has provided the defense with the birth month and year of each minor victim.62 In other words, as the Government has previously indicated, the discovery provides the defendant with more than sufficient information about the three minor victims to permit her to prepare for trial. The discovery also provides the defense the ability to identify specific private plane flights that are relevant to the Indictment. Any remaining detail regarding the specifics of abuse, particular interactions, and additional trips will come from witness testimony. As is to be expected when describing events more than two decades in the past, that testimony will provide approximate time periods when events occurred, rather than specific dates. Given the information the defendant already has from the discovery, the Indictment, and the Government's court filings (including this memorandum), any additional detail would essentially serve as early Jencks Act production, allowing the defendant to tailor any testimony to the Government's case. The discovery gives the defense ample information to assist in its investigation, and given the defense's",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "62 In this memorandum, the Government has also clarified that Minor Victim-3 was 17 years old at the time of the events described in the Indictment involving her. See Section VIII, supra.",
      "position": "footnote"
    },
    {
      "type": "printed",
      "content": "181",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00003142",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Minor Victim-3"
    ],
    "organizations": [
      "Government"
    ],
    "locations": [],
    "dates": [
      "04/16/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 204",
      "DOJ-OGR-00003142"
    ]
  },
  "additional_notes": "The document appears to be a court filing with redactions. The text is mostly clear, but some parts are blacked out."
}