{
  "document_metadata": {
    "page_number": "4",
    "document_number": "320",
    "date": "August 18, 2021",
    "document_type": "Court Document",
    "has_handwriting": false,
    "has_stamps": false
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  "full_text": "Case 1:20-cr-00330-PAE Document 320 Filed 08/18/21 Page 4 of 4\n\nHonorable Alison J. Nathan\nAugust 18, 2021\nPage 4\n\nInsofar as the defendant claims that identification of uncharged co-conspirators is necessary for her to interpose objections to the admissibility of co-conspirator statements (Dkt. No. 291 at 10-11), such an argument \"misunderstands the hearsay exception for the statements of co-conspirators.\" Murgio, 209 F. Supp. 3d at 722. The hearsay exception is \"rooted in agency law and is not constrained by the text of an indictment.\" Id. Accordingly, a co-conspirator statement may be admissible even if the conspiracy is not one charged in the indictment. And if the Government is not required to charge a conspiracy in the indictment in order to introduce statements by the defendant's co-conspirators in that conspiracy, it surely cannot be required to provide a bill of particulars as to a conspiracy charged in the indictment for that same purpose. See id. at 723.\n\nIn sum, the Government respectfully submits that the Court should not require the Government to provide an exhaustive list of co-conspirators, whether in a bill of particulars or otherwise.\n\nRespectfully submitted,\nAUDREY STRAUSS\nUnited States Attorney\n\nBy: /s/\nAlison Moe / Maurene Comey /\nLara Pomerantz / Andrew Rohrbach\nAssistant United States Attorneys\nSouthern District of New York\nTel: (212) 637-2225\n\nCc: All counsel of record (by ECF)\n\nwere only two co-conspirators or identify any others, which would \"meaningfully alter the nature of the charges\"); United States v. Akhavan, No. 20 Cr. 188, 2020 WL 2555333, at *2 (S.D.N.Y. May 20, 2020) (ordering the Government to identify alleged co-conspirators who \"represented several distinct organizations\" over three years, \"creat[ing] the possibility that different co-conspirators may have been involved at different times,\" presenting a high risk of surprise).\n\nDOJ-OGR-00004997",
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      "content": "Case 1:20-cr-00330-PAE Document 320 Filed 08/18/21 Page 4 of 4",
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    {
      "type": "printed",
      "content": "Honorable Alison J. Nathan\nAugust 18, 2021\nPage 4",
      "position": "top"
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      "type": "printed",
      "content": "Insofar as the defendant claims that identification of uncharged co-conspirators is necessary for her to interpose objections to the admissibility of co-conspirator statements (Dkt. No. 291 at 10-11), such an argument \"misunderstands the hearsay exception for the statements of co-conspirators.\" Murgio, 209 F. Supp. 3d at 722. The hearsay exception is \"rooted in agency law and is not constrained by the text of an indictment.\" Id. Accordingly, a co-conspirator statement may be admissible even if the conspiracy is not one charged in the indictment. And if the Government is not required to charge a conspiracy in the indictment in order to introduce statements by the defendant's co-conspirators in that conspiracy, it surely cannot be required to provide a bill of particulars as to a conspiracy charged in the indictment for that same purpose. See id. at 723.",
      "position": "middle"
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    {
      "type": "printed",
      "content": "In sum, the Government respectfully submits that the Court should not require the Government to provide an exhaustive list of co-conspirators, whether in a bill of particulars or otherwise.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Respectfully submitted,\nAUDREY STRAUSS\nUnited States Attorney\n\nBy: /s/\nAlison Moe / Maurene Comey /\nLara Pomerantz / Andrew Rohrbach\nAssistant United States Attorneys\nSouthern District of New York\nTel: (212) 637-2225",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Cc: All counsel of record (by ECF)",
      "position": "middle"
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    {
      "type": "printed",
      "content": "were only two co-conspirators or identify any others, which would \"meaningfully alter the nature of the charges\"); United States v. Akhavan, No. 20 Cr. 188, 2020 WL 2555333, at *2 (S.D.N.Y. May 20, 2020) (ordering the Government to identify alleged co-conspirators who \"represented several distinct organizations\" over three years, \"creat[ing] the possibility that different co-conspirators may have been involved at different times,\" presenting a high risk of surprise).",
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      "type": "printed",
      "content": "DOJ-OGR-00004997",
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  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Audrey Strauss",
      "Alison Moe",
      "Maurene Comey",
      "Lara Pomerantz",
      "Andrew Rohrbach",
      "Akhavan"
    ],
    "organizations": [
      "United States Attorney",
      "Southern District of New York"
    ],
    "locations": [
      "New York"
    ],
    "dates": [
      "August 18, 2021",
      "May 20, 2020"
    ],
    "reference_numbers": [
      "Case 1:20-cr-00330-PAE",
      "Document 320",
      "Dkt. No. 291",
      "No. 20 Cr. 188",
      "DOJ-OGR-00004997"
    ]
  },
  "additional_notes": "The document appears to be a court filing in a criminal case, with a formal tone and legal language. There are no visible redactions or damage to the document."
}