{
  "document_metadata": {
    "page_number": "71",
    "document_number": "397",
    "date": "10/29/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 397 Filed 10/29/21 Page 71 of 84\n\nprior to the incident,\" or alternatively, if \"if a witness gets a good look at the defendant during the course of a crime\"); United States v. Reed, No. 11 Cr. 487 (RJS), 2012 WL 2053758, at *5 (S.D.N.Y. June 6, 2012) (noting that a \"witness's familiarity with a suspect may establish that the identification . . . is independently reliable\").\n\nThis is not a crime in which a victim captures a fleeting glance of the perpetrator. Minor Victim-4 interacted with the defendant personally on multiple occasions between 2001 and 2004. She knew the defendant by name and gave a description. In the totality of the circumstances, it is plain that Minor Victim-4's identification of the defendant is sufficiently independently reliable to permit the jury to decide its persuasiveness.\n\nThe defense merely replies, again in conclusory fashion, that Minor Victim-4 (1) never identified the defendant as an abuser, (2) did not have an opportunity to view her during the crime because the defendant was not involved in a crime, (3) never described the defendant, and (4) the time between the abuse and the identification was extraordinarily long. (Def. Mot. 9 at 4). The first three of these points are inaccurate, as set forth above. And the delay in time is untroubling given Minor Victim-4's contacts with the defendant and consistent references in the intervening time. The defense is free to attempt to argue these points to the jury, but none of these arguments supports a motion to suppress Minor Victim-4's identification of the defendant.\n\nMinor Victim-4 knows who participated in the sexual abuse she experienced, as she has for the decades since it happened. This Court should deny the motion.\n\n70\n\nDOJ-OGR-00005854",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 397 Filed 10/29/21 Page 71 of 84",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "prior to the incident,\" or alternatively, if \"if a witness gets a good look at the defendant during the course of a crime\"); United States v. Reed, No. 11 Cr. 487 (RJS), 2012 WL 2053758, at *5 (S.D.N.Y. June 6, 2012) (noting that a \"witness's familiarity with a suspect may establish that the identification . . . is independently reliable\").",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "This is not a crime in which a victim captures a fleeting glance of the perpetrator. Minor Victim-4 interacted with the defendant personally on multiple occasions between 2001 and 2004. She knew the defendant by name and gave a description. In the totality of the circumstances, it is plain that Minor Victim-4's identification of the defendant is sufficiently independently reliable to permit the jury to decide its persuasiveness.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The defense merely replies, again in conclusory fashion, that Minor Victim-4 (1) never identified the defendant as an abuser, (2) did not have an opportunity to view her during the crime because the defendant was not involved in a crime, (3) never described the defendant, and (4) the time between the abuse and the identification was extraordinarily long. (Def. Mot. 9 at 4). The first three of these points are inaccurate, as set forth above. And the delay in time is untroubling given Minor Victim-4's contacts with the defendant and consistent references in the intervening time. The defense is free to attempt to argue these points to the jury, but none of these arguments supports a motion to suppress Minor Victim-4's identification of the defendant.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Minor Victim-4 knows who participated in the sexual abuse she experienced, as she has for the decades since it happened. This Court should deny the motion.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "70",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00005854",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Minor Victim-4",
      "Reed"
    ],
    "organizations": [
      "United States"
    ],
    "locations": [
      "S.D.N.Y."
    ],
    "dates": [
      "2001",
      "2004",
      "June 6, 2012",
      "10/29/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 397",
      "No. 11 Cr. 487 (RJS)",
      "2012 WL 2053758",
      "DOJ-OGR-00005854"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is printed and there are no visible stamps or handwritten notes. The document is well-formatted and easy to read."
}