mirror-epstein-docs/results/IMAGES002/DOJ-OGR-00003985.json

{
  "document_metadata": {
    "page_number": "14",
    "document_number": "244",
    "date": "04/23/21",
    "document_type": "court document",
    "has_handwriting": true,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 244 Filed 04/23/21 Page 14 of 14\nThe Honorable Alison J. Nathan\nApril 2, 2021\nPage 14\nSee also United States v. Petrillo, 821 F.2d 85, 90 (2d Cir.1987) (explaining impeachment evidence of uncorroborated testimony is material where the witness \"whose credibility was at issue supplied the only evidence linking the defendant[ ] to the crime\"); Grant v. Alldredge, 498 F.2d 376, 382 (2d Cir.1974) (finding a Brady violation occurred where the prosecution did not disclose that a witness identified someone other than the accused); United States v. Wilkins, 326 F .2d 135, 140 (2d Cir.1964) (where the state's case depended on the positive identification by two witnesses, the existence of two other witnesses who would testify the defendant was not the perpetrator of the crime was material).\nBecause the EVCP Material constitutes exculpatory evidence, it is procurable by subpoena in advance of trial.\nConclusion\nFor the foregoing reasons, this Court should deny BSF's Motion to Quash and enforce the proposed subpoena on BSF.\nRespectfully Submitted,\nJeffrey S. Pagliuca\nCC: Sigrid McCawley, David Boies",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 244 Filed 04/23/21 Page 14 of 14",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "The Honorable Alison J. Nathan\nApril 2, 2021\nPage 14",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "See also United States v. Petrillo, 821 F.2d 85, 90 (2d Cir.1987) (explaining impeachment evidence of uncorroborated testimony is material where the witness \"whose credibility was at issue supplied the only evidence linking the defendant[ ] to the crime\"); Grant v. Alldredge, 498 F.2d 376, 382 (2d Cir.1974) (finding a Brady violation occurred where the prosecution did not disclose that a witness identified someone other than the accused); United States v. Wilkins, 326 F .2d 135, 140 (2d Cir.1964) (where the state's case depended on the positive identification by two witnesses, the existence of two other witnesses who would testify the defendant was not the perpetrator of the crime was material).",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Because the EVCP Material constitutes exculpatory evidence, it is procurable by subpoena in advance of trial.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Conclusion",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "For the foregoing reasons, this Court should deny BSF's Motion to Quash and enforce the proposed subpoena on BSF.",
      "position": "middle"
    },
    {
      "type": "handwritten",
      "content": "Jeffrey S. Pagliuca",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "Respectfully Submitted,",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "CC: Sigrid McCawley, David Boies",
      "position": "bottom"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Jeffrey S. Pagliuca",
      "Sigrid McCawley",
      "David Boies"
    ],
    "organizations": [
      "BSF"
    ],
    "locations": [],
    "dates": [
      "April 2, 2021",
      "04/23/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 244"
    ]
  },
  "additional_notes": "The document appears to be a court filing with a signature at the bottom. The text is mostly printed, with a handwritten signature."
}