mirror-epstein-docs/results/IMAGES002/DOJ-OGR-00003705.json

{
  "document_metadata": {
    "page_number": "31",
    "document_number": "207",
    "date": "04/16/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 207 Filed 04/16/21 Page 31 of 34\nhas committed to producing co-conspirator statements at least six weeks in advance of trial to allow Maxwell to raise any objections. Maxwell will have adequate time to object to any proffered co-conspirator testimony following the Government's Jencks Act disclosures.\nC. Witness list\nAs a general matter, \"district courts have authority to compel pretrial disclosure of the identity of government witnesses.\" United States v. Cannone, 528 F.2d 296, 300 (2d Cir. 1975).\nIn deciding whether to order accelerated disclosure of a witness list, courts consider whether a defendant has made a specific showing that disclosure is \"both material to the preparation of the defense and reasonable in light of the circumstances surrounding the case.\" United States v. Bejasa, 904 F.2d 137, 139-140 (2d Cir. 1990) (cleaned up).\nMaxwell has made a particularized showing that the Government must produce a witness list reasonably in advance of trial. The nature of the allegations in this case—decades-old allegations spanning multiple locations—present considerable challenges for the preparation of the defense. However, the Government's proposed disclosure schedule—which will afford Maxwell at least six weeks to investigate testifying witness statements—allows Maxwell significantly more time to review disclosures than schedules adopted in most cases in this District. See, e.g., United States v. Rueb, No. 00-CR-91 (RWS), 2001 WL 96177, at *9 (S.D.N.Y. Feb. 5, 2001) (thirty days before trial); United States v. Nachamie, 91 F. Supp. 2d 565, 580 (S.D.N.Y. 2000) (fourteen days before trial). In addition, on April 13, 2021, the Government produced over 20,000 pages of interview notes, reports and other materials related to non-testifying witnesses. After considering the circumstances, including the complexity of the issues in this case and what the defense has already received and likely learned in the course of discovery, the Court concludes that the Government's proposal is generally reasonable.\n31\nDOJ-OGR-00003705",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 207 Filed 04/16/21 Page 31 of 34\nhas committed to producing co-conspirator statements at least six weeks in advance of trial to allow Maxwell to raise any objections. Maxwell will have adequate time to object to any proffered co-conspirator testimony following the Government's Jencks Act disclosures.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "C. Witness list\nAs a general matter, \"district courts have authority to compel pretrial disclosure of the identity of government witnesses.\" United States v. Cannone, 528 F.2d 296, 300 (2d Cir. 1975).\nIn deciding whether to order accelerated disclosure of a witness list, courts consider whether a defendant has made a specific showing that disclosure is \"both material to the preparation of the defense and reasonable in light of the circumstances surrounding the case.\" United States v. Bejasa, 904 F.2d 137, 139-140 (2d Cir. 1990) (cleaned up).",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Maxwell has made a particularized showing that the Government must produce a witness list reasonably in advance of trial. The nature of the allegations in this case—decades-old allegations spanning multiple locations—present considerable challenges for the preparation of the defense. However, the Government's proposed disclosure schedule—which will afford Maxwell at least six weeks to investigate testifying witness statements—allows Maxwell significantly more time to review disclosures than schedules adopted in most cases in this District. See, e.g., United States v. Rueb, No. 00-CR-91 (RWS), 2001 WL 96177, at *9 (S.D.N.Y. Feb. 5, 2001) (thirty days before trial); United States v. Nachamie, 91 F. Supp. 2d 565, 580 (S.D.N.Y. 2000) (fourteen days before trial). In addition, on April 13, 2021, the Government produced over 20,000 pages of interview notes, reports and other materials related to non-testifying witnesses. After considering the circumstances, including the complexity of the issues in this case and what the defense has already received and likely learned in the course of discovery, the Court concludes that the Government's proposal is generally reasonable.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "31",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00003705",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Maxwell"
    ],
    "organizations": [
      "Government",
      "Court"
    ],
    "locations": [
      "S.D.N.Y."
    ],
    "dates": [
      "04/16/21",
      "April 13, 2021",
      "Feb. 5, 2001"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 207",
      "00-CR-91 (RWS)",
      "DOJ-OGR-00003705"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case United States v. Maxwell. The text is printed and there are no visible stamps or handwritten notes. The document is page 31 of 34."
}