{ "document_metadata": { "page_number": "158", "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 158 of 239 long as the question involves a phrase \"which could be used with mutual understanding by a questioner and answerer,\" it is not fundamentally ambiguous. Id. at 375 (internal quotation marks omitted); see United States v. Jenkins, 727 F. App'x 732, 735 (2d Cir. 2018) (\"An individual of ordinary intelligence would not think that a question asking for information regarding 'real estate, stocks, bonds, . . . or other valuable property' would allow omission of information regarding money market funds . . .\"). The use of broad or inclusive terms does not render the question fundamentally ambiguous. As the Second Circuit explained in the context of the term \"employment activities,\" \"[t]he broad language of the question is not fundamentally ambiguous; it is instead designed to capture all employment activities in an applicant's recent history.\" United States v. Polos, 723 F. App'x 64, 65-66 (2d Cir. 2018). So too here. A \"sex toy or device\" is an intelligible phrase with an understood meaning. See Sex Toy, Oxford English Dictionary Online, https://www.oed.com/view/Entry/176989 (last visited February 12, 2021) (\"[A] device or object designed for sexual stimulation (as a dildo, vibrator, etc.) or to enhance sexual pleasure or performance.\"). The defendant's objections to the next colloquy in the indictment are similarly unavailing. Shortly after the above exchange, the following conversation occurred: 131 DOJ-OGR-00003092", "text_blocks": [ { "type": "printed", "content": "Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 158 of 239", "position": "header" }, { "type": "printed", "content": "long as the question involves a phrase \"which could be used with mutual understanding by a questioner and answerer,\" it is not fundamentally ambiguous. Id. at 375 (internal quotation marks omitted); see United States v. Jenkins, 727 F. App'x 732, 735 (2d Cir. 2018) (\"An individual of ordinary intelligence would not think that a question asking for information regarding 'real estate, stocks, bonds, . . . or other valuable property' would allow omission of information regarding money market funds . . .\"). The use of broad or inclusive terms does not render the question fundamentally ambiguous. As the Second Circuit explained in the context of the term \"employment activities,\" \"[t]he broad language of the question is not fundamentally ambiguous; it is instead designed to capture all employment activities in an applicant's recent history.\" United States v. Polos, 723 F. App'x 64, 65-66 (2d Cir. 2018). So too here. A \"sex toy or device\" is an intelligible phrase with an understood meaning. See Sex Toy, Oxford English Dictionary Online, https://www.oed.com/view/Entry/176989 (last visited February 12, 2021) (\"[A] device or object designed for sexual stimulation (as a dildo, vibrator, etc.) or to enhance sexual pleasure or performance.\").", "position": "main" }, { "type": "printed", "content": "The defendant's objections to the next colloquy in the indictment are similarly unavailing. Shortly after the above exchange, the following conversation occurred:", "position": "main" }, { "type": "printed", "content": "131", "position": "footer" }, { "type": "printed", "content": "DOJ-OGR-00003092", "position": "footer" } ], "entities": { "people": [], "organizations": [ "Oxford English Dictionary Online", "Second Circuit" ], "locations": [], "dates": [ "04/16/21", "February 12, 2021" ], "reference_numbers": [ "1:20-cr-00330-PAE", "204", "158", "239", "727 F. App'x 732", "723 F. App'x 64", "DOJ-OGR-00003092" ] }, "additional_notes": "The document appears to be a court filing with redactions. The text is mostly printed, with no visible handwriting or stamps. The redactions are likely due to sensitive information being removed." }