{
  "document_metadata": {
    "page_number": "12 of 12",
    "document_number": "706",
    "date": "07/12/22",
    "document_type": "Court Document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 706 Filed 07/12/22 Page 12 of 12\n\nThe Government has no objection to fact testimony from Lopez about the admitted exhibits. On December 13, however, defense counsel informed the Government that they may receive and produce financial records about which they would ask John Lopez to testify. Such records have not been produced to the Government as of the time of this letter. The Court should not permit the defense to produce and introduce additional financial records between now and Lopez's testimony. The account statements showing the financial transactions that the Government proved at trial were all produced to the defense more than a year before trial. Production of new exhibits at this late date would violate Rule 16 and would likely prejudice the Government.\n\nVI. Conclusion\n\nFor the reasons set forth above, the Court should deny the defendant's motion.\n\nRespectfully submitted,\n\nDAMIAN WILLIAMS\nUnited States Attorney\n\nBy: /s/\nMaurene Comey\nAlison Moe\nLara Pomerantz\nAndrew Rohrbach\nAssistant United States Attorneys\nSouthern District of New York\n\nCc: Defense Counsel (by e-mail)\n\n12\nDOJ-OGR-00011264",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 706 Filed 07/12/22 Page 12 of 12",
      "position": "header"
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    {
      "type": "printed",
      "content": "The Government has no objection to fact testimony from Lopez about the admitted exhibits. On December 13, however, defense counsel informed the Government that they may receive and produce financial records about which they would ask John Lopez to testify. Such records have not been produced to the Government as of the time of this letter. The Court should not permit the defense to produce and introduce additional financial records between now and Lopez's testimony. The account statements showing the financial transactions that the Government proved at trial were all produced to the defense more than a year before trial. Production of new exhibits at this late date would violate Rule 16 and would likely prejudice the Government.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "VI. Conclusion",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "For the reasons set forth above, the Court should deny the defendant's motion.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Respectfully submitted,",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "DAMIAN WILLIAMS\nUnited States Attorney",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "By: /s/\nMaurene Comey\nAlison Moe\nLara Pomerantz\nAndrew Rohrbach\nAssistant United States Attorneys\nSouthern District of New York",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Cc: Defense Counsel (by e-mail)",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "12",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00011264",
      "position": "footer"
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  ],
  "entities": {
    "people": [
      "Lopez",
      "John Lopez",
      "DAMIAN WILLIAMS",
      "Maurene Comey",
      "Alison Moe",
      "Lara Pomerantz",
      "Andrew Rohrbach"
    ],
    "organizations": [
      "United States Attorney",
      "Southern District of New York"
    ],
    "locations": [
      "New York"
    ],
    "dates": [
      "December 13",
      "07/12/22"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "706",
      "DOJ-OGR-00011264"
    ]
  },
  "additional_notes": "The document appears to be a court filing with a clear and legible format. There are no visible redactions or damage."
}