{
  "document_metadata": {
    "page_number": "8",
    "document_number": "120",
    "date": "01/25/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 120 Filed 01/25/21 Page 8 of 19\n\nBlakney, 941 F.2d 114, 116 (2d Cir. 1991) (quotations and citation omitted). “‘Similar’ charges include those that are ‘somewhat alike,’ or those ‘having a general likeness’ to each other.” United States v. Rivera, 546 F.3d 245, 253 (2d Cir. 2008) (quoting Werner, 620 F.2d at 926). Offenses are “connected” or part of a “common scheme or plan” if the counts “grow out of related transactions.” United States v. Randazzo, 80 F.3d 623, 627 (1st Cir. 1996). By contrast, offenses are not “connected” and joinder is inappropriate when “[c]ommission of one of the offenses neither depended upon nor necessarily led to the commission of the other; proof of the one act neither constituted nor depended upon proof of the other.” Halper, 590 F.2d at 429.\n\nSimilarly, offenses that are separated by time and location, and were allegedly committed under different circumstances, are not sufficiently connected to warrant joinder. See United States v. Martinez, Nos. S2 92 Cr. 839 (SWK), 1993 WL 322768, at *8-*9 (S.D.N.Y. Aug. 19, 1993) (granting severance of firearm possession and narcotics conspiracy counts where firearm was seized in different location over four months after narcotics conspiracy ended “under circumstances having no bearing on either the alleged narcotics conspiracy, or any of [defendant’s] coconspirators”); United States v. Brown, No. 07-0296-1, 2008 WL 161146, at *5 (E.D. Pa. Jan. 16, 2008) (granting severance where a firearm possession count was unrelated “both physically and temporally” to the narcotics counts in the indictment (emphasis original).\n\nAlthough the Second Circuit has recognized that it is generally permissible to join “underlying substantive crimes with perjury counts” where the false declarations “concern the substantive offenses,” United States v. Potamitis, 739 F.2d 784 (2d Cir. 1984), joinder is not appropriate when the perjury or false statement allegations do not relate to, or have only a speculative connection to, the other charges in the indictment. See United States v. Botti, No. 3:08-cr-00230 (CSH), 2009 WL 3157582, at *5 (S.D.N.Y. Sept. 25, 2009) (severing structuring\n\n4\n\nDOJ-OGR-00002286",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 120 Filed 01/25/21 Page 8 of 19",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Blakney, 941 F.2d 114, 116 (2d Cir. 1991) (quotations and citation omitted). “‘Similar’ charges include those that are ‘somewhat alike,’ or those ‘having a general likeness’ to each other.” United States v. Rivera, 546 F.3d 245, 253 (2d Cir. 2008) (quoting Werner, 620 F.2d at 926). Offenses are “connected” or part of a “common scheme or plan” if the counts “grow out of related transactions.” United States v. Randazzo, 80 F.3d 623, 627 (1st Cir. 1996). By contrast, offenses are not “connected” and joinder is inappropriate when “[c]ommission of one of the offenses neither depended upon nor necessarily led to the commission of the other; proof of the one act neither constituted nor depended upon proof of the other.” Halper, 590 F.2d at 429.",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "Similarly, offenses that are separated by time and location, and were allegedly committed under different circumstances, are not sufficiently connected to warrant joinder. See United States v. Martinez, Nos. S2 92 Cr. 839 (SWK), 1993 WL 322768, at *8-*9 (S.D.N.Y. Aug. 19, 1993) (granting severance of firearm possession and narcotics conspiracy counts where firearm was seized in different location over four months after narcotics conspiracy ended “under circumstances having no bearing on either the alleged narcotics conspiracy, or any of [defendant’s] coconspirators”); United States v. Brown, No. 07-0296-1, 2008 WL 161146, at *5 (E.D. Pa. Jan. 16, 2008) (granting severance where a firearm possession count was unrelated “both physically and temporally” to the narcotics counts in the indictment (emphasis original).",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "Although the Second Circuit has recognized that it is generally permissible to join “underlying substantive crimes with perjury counts” where the false declarations “concern the substantive offenses,” United States v. Potamitis, 739 F.2d 784 (2d Cir. 1984), joinder is not appropriate when the perjury or false statement allegations do not relate to, or have only a speculative connection to, the other charges in the indictment. See United States v. Botti, No. 3:08-cr-00230 (CSH), 2009 WL 3157582, at *5 (S.D.N.Y. Sept. 25, 2009) (severing structuring",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "4",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00002286",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Blakney",
      "Rivera",
      "Werner",
      "Randazzo",
      "Halper",
      "Martinez",
      "Brown",
      "Potamitis",
      "Botti"
    ],
    "organizations": [
      "United States"
    ],
    "locations": [
      "S.D.N.Y.",
      "E.D. Pa."
    ],
    "dates": [
      "01/25/21",
      "Aug. 19, 1993",
      "Jan. 16, 2008",
      "Sept. 25, 2009"
    ],
    "reference_numbers": [
      "Case 1:20-cr-00330-AJN",
      "Document 120",
      "941 F.2d 114",
      "546 F.3d 245",
      "620 F.2d",
      "80 F.3d 623",
      "590 F.2d",
      "S2 92 Cr. 839",
      "No. 07-0296-1",
      "739 F.2d 784",
      "No. 3:08-cr-00230"
    ]
  },
  "additional_notes": "The document appears to be a court filing discussing the joinder of offenses in a criminal case. The text is printed and there are no visible stamps or handwritten notes. The document is likely a page from a larger filing."
}