{ "document_metadata": { "page_number": "3", "document_number": "227", "date": "04/21/21", "document_type": "court document", "has_handwriting": false, "has_stamps": false }, "full_text": "Case 1:20-cr-00330-PAE Document 227 Filed 04/21/21 Page 3 of 3\nPage 3\nWalder, 347 U.S. at 65.\nAccordingly, the Court need not resolve the pending suppression motions, because the Government does not intend to use these materials in its case-in-chief. However, to the extent the defendant puts these materials at issue at trial either through the defense case or cross-examination, the Government reserves its right to use these materials, for example, to cross-examine the defendant, or to offer prior consistent statements of witnesses, should it be appropriate to do so. In addition, the Government further reserves its right to use these materials at trial for any purpose that would be permissible under the Federal Rules of Evidence, even assuming these materials were suppressed.\nRespectfully submitted,\nAUDREY STRAUSS\nUnited States Attorney\nBy: /s\nAlison Moe / Maurene Comey\nLara Pomerantz / Andrew Rohrbach\nAssistant United States Attorneys\nSouthern District of New York\nCc: All Counsel of Record (By ECF)", "text_blocks": [ { "type": "printed", "content": "Case 1:20-cr-00330-PAE Document 227 Filed 04/21/21 Page 3 of 3", "position": "header" }, { "type": "printed", "content": "Page 3", "position": "header" }, { "type": "printed", "content": "Walder, 347 U.S. at 65.\nAccordingly, the Court need not resolve the pending suppression motions, because the Government does not intend to use these materials in its case-in-chief. However, to the extent the defendant puts these materials at issue at trial either through the defense case or cross-examination, the Government reserves its right to use these materials, for example, to cross-examine the defendant, or to offer prior consistent statements of witnesses, should it be appropriate to do so. In addition, the Government further reserves its right to use these materials at trial for any purpose that would be permissible under the Federal Rules of Evidence, even assuming these materials were suppressed.", "position": "main body" }, { "type": "printed", "content": "Respectfully submitted,", "position": "main body" }, { "type": "printed", "content": "AUDREY STRAUSS\nUnited States Attorney", "position": "main body" }, { "type": "printed", "content": "By: /s\nAlison Moe / Maurene Comey\nLara Pomerantz / Andrew Rohrbach\nAssistant United States Attorneys\nSouthern District of New York", "position": "main body" }, { "type": "printed", "content": "Cc: All Counsel of Record (By ECF)", "position": "footer" } ], "entities": { "people": [ "Audrey Strauss", "Alison Moe", "Maurene Comey", "Lara Pomerantz", "Andrew Rohrbach" ], "organizations": [ "United States Attorney", "Southern District of New York" ], "locations": [ "New York" ], "dates": [ "04/21/21" ], "reference_numbers": [ "1:20-cr-00330-PAE", "227" ] }, "additional_notes": "The document appears to be a court filing in a criminal case, with a clear and legible format. There are no visible redactions or damage to the document." }