{
  "document_metadata": {
    "page_number": "9",
    "document_number": "701",
    "date": "07/12/22",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 701 Filed 07/12/22 Page 9 of 10\n\nGovernment is able to “prepare a meaningful cross-examination”), and is not called for under these circumstances. At most, the Court should permit the defense additional time to prepare their cross-examination of Flatley.\n\nFinally, the Government notes that the defendant has given far less detailed expert notice than the Government has, despite the Court’s order for the defendant to supplement her expert notice. (See 11/23/21 Tr. at 25 (directing the defense to supplement their notice by November 27)). A copy of the defense supplemental letter is attached as Exhibit B. For instance, a principal defense concern at the Final Pretrial Conference concerned a lack of certainty about the “methods that [Flatley’s] used” to extract data and uncertainty about “exactly what documents Mr. Flatley intends to refer to.” (Id. at 21, 23). The Government’s November 26 letter identifies the specific methods Flatley used and the specific exhibits about which he will testify. The defendant’s November 27 letter identifies neither any methods nor any specific exhibits. The defendant’s expert notice should at a minimum be held to the same standard as the Government. But there are certainly no grounds for the defendant to challenge the sufficiency of the Government’s detailed expert notice.\n\nIV. Conclusion\n\nFor the foregoing reasons, the Court should deny the defendant’s motion to preclude.\n\n9\n\nDOJ-OGR-00011188",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 701 Filed 07/12/22 Page 9 of 10",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Government is able to “prepare a meaningful cross-examination”), and is not called for under these circumstances. At most, the Court should permit the defense additional time to prepare their cross-examination of Flatley.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Finally, the Government notes that the defendant has given far less detailed expert notice than the Government has, despite the Court’s order for the defendant to supplement her expert notice. (See 11/23/21 Tr. at 25 (directing the defense to supplement their notice by November 27)). A copy of the defense supplemental letter is attached as Exhibit B. For instance, a principal defense concern at the Final Pretrial Conference concerned a lack of certainty about the “methods that [Flatley’s] used” to extract data and uncertainty about “exactly what documents Mr. Flatley intends to refer to.” (Id. at 21, 23). The Government’s November 26 letter identifies the specific methods Flatley used and the specific exhibits about which he will testify. The defendant’s November 27 letter identifies neither any methods nor any specific exhibits. The defendant’s expert notice should at a minimum be held to the same standard as the Government. But there are certainly no grounds for the defendant to challenge the sufficiency of the Government’s detailed expert notice.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "IV. Conclusion",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "For the foregoing reasons, the Court should deny the defendant’s motion to preclude.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "9",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00011188",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Flatley",
      "Mr. Flatley"
    ],
    "organizations": [
      "Government",
      "Court",
      "DOJ"
    ],
    "locations": [],
    "dates": [
      "07/12/22",
      "11/23/21",
      "November 27",
      "November 26"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 701",
      "DOJ-OGR-00011188",
      "Exhibit B"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is well-formatted and printed, with no visible handwriting or stamps. The document is page 9 of 10."
}