{
  "document_metadata": {
    "page_number": "13",
    "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 13 of 23\nthe government further advised that, to the extent it had access to an unredacted copy of the report, it would produce it when it produces Giglio material.\nThe defense believes that these reports contain Brady material and should be produced immediately.\n\n\n\n\n\n\n\nIt is the government's responsibility to obtain unredacted copies of these reports and produce them to the defense. The government cannot absolve itself of its Brady obligations by producing redacted documents \"as is,\" when they could easily obtain unredacted copies from the FBI. See Kyles v. Whitley, 514 U.S. 419, 437 (1995) (the government \"has a duty to learn of any favorable evidence known to the others acting on the government's behalf in the case, including the police\"). An informed witness who fails to mention the defendant when making a police report is certainly exculpatory under Brady. United States v. Torres, 719 F.2d 549, 555-56 (2d Cir. 1983); Jones v. Jago, 575 F.2d 1164, 1168 (6th Cir. 1978); Clemmons v. Delo, 124 F.3d 944, 952 (8th Cir. 1997); White v. Helling, 194 F.3d 937, 944 (8th Cir. 1999).\nThe timing for Brady disclosures is now. As this Court ruled:\n\"The Government must disclose to the defense all information 'favorable to an accused' that is 'material either to guilt or to punishment' and that is known to the Government. . . . The Government shall disclose such information to the defense promptly after its existence becomes known to the Government so that the defense may make effective use of the information in the preparation of its case.\"\n9\nDOJ-OGR-00002706",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 148 Filed 02/04/21 Page 13 of 23",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "the government further advised that, to the extent it had access to an unredacted copy of the report, it would produce it when it produces Giglio material.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The defense believes that these reports contain Brady material and should be produced immediately.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "It is the government's responsibility to obtain unredacted copies of these reports and produce them to the defense. The government cannot absolve itself of its Brady obligations by producing redacted documents \"as is,\" when they could easily obtain unredacted copies from the FBI. See Kyles v. Whitley, 514 U.S. 419, 437 (1995) (the government \"has a duty to learn of any favorable evidence known to the others acting on the government's behalf in the case, including the police\"). An informed witness who fails to mention the defendant when making a police report is certainly exculpatory under Brady. United States v. Torres, 719 F.2d 549, 555-56 (2d Cir. 1983); Jones v. Jago, 575 F.2d 1164, 1168 (6th Cir. 1978); Clemmons v. Delo, 124 F.3d 944, 952 (8th Cir. 1997); White v. Helling, 194 F.3d 937, 944 (8th Cir. 1999).",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The timing for Brady disclosures is now. As this Court ruled:",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "\"The Government must disclose to the defense all information 'favorable to an accused' that is 'material either to guilt or to punishment' and that is known to the Government. . . . The Government shall disclose such information to the defense promptly after its existence becomes known to the Government so that the defense may make effective use of the information in the preparation of its case.\"",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "9",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00002706",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [],
    "organizations": [
      "FBI",
      "Government"
    ],
    "locations": [],
    "dates": [
      "02/04/21",
      "1995",
      "1983",
      "1978",
      "1997",
      "1999"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "148",
      "514 U.S. 419",
      "719 F.2d 549",
      "575 F.2d 1164",
      "124 F.3d 944",
      "194 F.3d 937",
      "DOJ-OGR-00002706"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case, discussing the government's obligations under Brady v. Maryland to disclose exculpatory evidence to the defense. The document contains citations to various court cases and legal precedents."
}