mirror-epstein-docs/results/IMAGES008/DOJ-OGR-00022081.json

{
  "document_metadata": {
    "page_number": "19",
    "document_number": "35",
    "date": "04/24/20",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:19-cr-00830-AT Document 35 Filed 04/24/20 Page 19 of 34\nwere not on trial).\nThomas's efforts to garner sympathy, put the Government on trial, and deflect blame for his own criminal actions plainly sound in nullification. See Reese, 933 F. Supp. 2d at 583-84; Levin, 2016 WL 2990831, at *12. Evidence on those points does not relate to whether the defendant committed the crimes charged, but rather is intended to elicit sympathy, compassion, or compromise from the jury. The records Thomas seeks are no more discoverable than the nullification evidence precluded in Armstrong and its progeny. See Armstrong, 517 U.S. at 462-63 (defendant not entitled to discovery on race of other narcotics defendants to aid in selective prosecution claim); United States v. Delacruz, No. 14 Cr. 815 (KBF), 2015 WL 2211943, at *4 (S.D.N.Y. May 12, 2015) (rejecting defendant's \"demands for general information and statistics relating to the Government's use of sting operations\"); United States v. Floyd, No. 99 Cr. 0234 (DAB), 1999 WL 476438, at *2 (S.D.N.Y. July 7, 1999) (rejecting discovery request for \"background data, records and investigative reports\" of the New York City Police Department (\"NYPD\") as well as information about NYPD officers' conduct in other cases); Defreitas, 2011 WL 317964, at *10 (rejecting discovery demands related to a \"factual impossibility\" defense to a conspiracy charge). It is the Court's \"duty to forestall or prevent\" jury nullification. Manzano, 945 F.3d at 627 (holding that \"District courts have a duty to forestall or prevent [jury nullification arguments] and the district court in this case abdicated its duty by ruling that defense counsel could argue jury nullification.\"); see also United States v. Rosado, 728 F.2d 89, 93 (2d Cir. 1984) (criticizing trial court for inviting nullification by permitting the defendants to mount a \"political defense\" and stating that it was an \"erroneous assumption that good motive for committing a crime is inconsistent with criminal intent\").\nIn sum, much of the additional discovery Thomas seeks in his motion relates to legally\n14\nDOJ-OGR-00022081",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:19-cr-00830-AT Document 35 Filed 04/24/20 Page 19 of 34",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "were not on trial).\nThomas's efforts to garner sympathy, put the Government on trial, and deflect blame for his own criminal actions plainly sound in nullification. See Reese, 933 F. Supp. 2d at 583-84; Levin, 2016 WL 2990831, at *12. Evidence on those points does not relate to whether the defendant committed the crimes charged, but rather is intended to elicit sympathy, compassion, or compromise from the jury. The records Thomas seeks are no more discoverable than the nullification evidence precluded in Armstrong and its progeny. See Armstrong, 517 U.S. at 462-63 (defendant not entitled to discovery on race of other narcotics defendants to aid in selective prosecution claim); United States v. Delacruz, No. 14 Cr. 815 (KBF), 2015 WL 2211943, at *4 (S.D.N.Y. May 12, 2015) (rejecting defendant's \"demands for general information and statistics relating to the Government's use of sting operations\"); United States v. Floyd, No. 99 Cr. 0234 (DAB), 1999 WL 476438, at *2 (S.D.N.Y. July 7, 1999) (rejecting discovery request for \"background data, records and investigative reports\" of the New York City Police Department (\"NYPD\") as well as information about NYPD officers' conduct in other cases); Defreitas, 2011 WL 317964, at *10 (rejecting discovery demands related to a \"factual impossibility\" defense to a conspiracy charge). It is the Court's \"duty to forestall or prevent\" jury nullification. Manzano, 945 F.3d at 627 (holding that \"District courts have a duty to forestall or prevent [jury nullification arguments] and the district court in this case abdicated its duty by ruling that defense counsel could argue jury nullification.\"); see also United States v. Rosado, 728 F.2d 89, 93 (2d Cir. 1984) (criticizing trial court for inviting nullification by permitting the defendants to mount a \"political defense\" and stating that it was an \"erroneous assumption that good motive for committing a crime is inconsistent with criminal intent\").",
      "position": "main body"
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    {
      "type": "printed",
      "content": "In sum, much of the additional discovery Thomas seeks in his motion relates to legally",
      "position": "main body"
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    {
      "type": "printed",
      "content": "14",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00022081",
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  ],
  "entities": {
    "people": [
      "Thomas",
      "Reese",
      "Levin",
      "Armstrong",
      "Delacruz",
      "Floyd",
      "Defreitas",
      "Manzano",
      "Rosado"
    ],
    "organizations": [
      "Government",
      "NYPD",
      "Court",
      "District courts"
    ],
    "locations": [
      "New York"
    ],
    "dates": [
      "04/24/20",
      "May 12, 2015",
      "July 7, 1999"
    ],
    "reference_numbers": [
      "1:19-cr-00830-AT",
      "Document 35",
      "933 F. Supp. 2d",
      "2016 WL 2990831",
      "517 U.S. at 462-63",
      "14 Cr. 815 (KBF)",
      "2015 WL 2211943",
      "99 Cr. 0234 (DAB)",
      "1999 WL 476438",
      "2011 WL 317964",
      "945 F.3d",
      "728 F.2d 89",
      "DOJ-OGR-00022081"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is mostly printed, with no handwritten content or stamps visible. The document is well-formatted and legible."
}