mirror-epstein-docs/results/IMAGES003/DOJ-OGR-00005964.json

{
  "document_metadata": {
    "page_number": "9",
    "document_number": "398",
    "date": "10/29/21",
    "document_type": "court document",
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    "has_stamps": false
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  "full_text": "Case 1:20-cr-00330-PAE Document 398 Filed 10/29/21 Page 9 of 52\n\nIn United States v. Velez, No. 3:10CR147 JBA, 2010 WL 4929266, at *7 (D. Conn. Nov. 30, 2010), the defendant moved for disclosure of any co-conspirator statements in advance of trial. In response, the government agreed to disclose \"well in advance of trial, exactly which of the intercepted telephone calls will be offered as full exhibits at trial and transcripts of those calls will be provided in advance of trial.\" Based on that representation the court denied the motion to produce as moot, \"without prejudice to renew if the Government fails to comply with its ongoing disclosure obligations.\" Id.\n\nIn United States v. Smalls, No. CR 06-2403 RB, 2008 WL 11361098, at *8-9 (D.N.M. Jan. 24, 2008), the court's order was very detailed:\n\nThe United States is hereby instructed to:\n\nfile a supplemental brief identifying the summary witness; specifically identifying each and every coconspirator statement it intends to offer at trial as evidence against Defendants pursuant to Fed. R. Evid. 801(d)(2)(E); and stating how each proffered statement satisfies the requirements of Rule 801(d)(2)(E). Specifically, with respect to each alleged coconspirator statement, the United States must indicate: a) the identity of the coconspirator who made the alleged statement; b) the identity of the person or persons to whom the coconspirator statement was made; c) the identity of the witness who will testify at trial about the coconspirator statement; d) the content of the coconspirator statement; e) when the statement was made; f) how the statement is in the course of the alleged conspiracy; and g) how the statement is in furtherance of the alleged conspiracy. Additionally, the United States must identify the independent evidence it intends to offer in support of admission of the alleged coconspirator statements.\n\nSee also United States v. Brewington, No. 15-CR-00073-PAB, 2018 WL 1411274, at *3 (D. Colo. Mar. 21, 2018) (court required the government to identify and produce all its purported 801(d)(2)(e) statements, in the hundreds; held an evidentiary pre-trial hearing about the admissibility of those statements; and made detailed, statement by statement rulings about admissibility, excluding some and conditionally admitting others); United States v. Bozeman, No. 3:11-CR-129, 2012 WL 1071207, at *14 (E.D. Tenn. Mar. 29, 2012), aff'd, No. 3:11-CR-\n\n3\n\nDOJ-OGR-00005964",
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    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 398 Filed 10/29/21 Page 9 of 52",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "In United States v. Velez, No. 3:10CR147 JBA, 2010 WL 4929266, at *7 (D. Conn. Nov. 30, 2010), the defendant moved for disclosure of any co-conspirator statements in advance of trial. In response, the government agreed to disclose \"well in advance of trial, exactly which of the intercepted telephone calls will be offered as full exhibits at trial and transcripts of those calls will be provided in advance of trial.\" Based on that representation the court denied the motion to produce as moot, \"without prejudice to renew if the Government fails to comply with its ongoing disclosure obligations.\" Id.",
      "position": "main body"
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    {
      "type": "printed",
      "content": "In United States v. Smalls, No. CR 06-2403 RB, 2008 WL 11361098, at *8-9 (D.N.M. Jan. 24, 2008), the court's order was very detailed:",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "The United States is hereby instructed to:\n\nfile a supplemental brief identifying the summary witness; specifically identifying each and every coconspirator statement it intends to offer at trial as evidence against Defendants pursuant to Fed. R. Evid. 801(d)(2)(E); and stating how each proffered statement satisfies the requirements of Rule 801(d)(2)(E). Specifically, with respect to each alleged coconspirator statement, the United States must indicate: a) the identity of the coconspirator who made the alleged statement; b) the identity of the person or persons to whom the coconspirator statement was made; c) the identity of the witness who will testify at trial about the coconspirator statement; d) the content of the coconspirator statement; e) when the statement was made; f) how the statement is in the course of the alleged conspiracy; and g) how the statement is in furtherance of the alleged conspiracy. Additionally, the United States must identify the independent evidence it intends to offer in support of admission of the alleged coconspirator statements.",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "See also United States v. Brewington, No. 15-CR-00073-PAB, 2018 WL 1411274, at *3 (D. Colo. Mar. 21, 2018) (court required the government to identify and produce all its purported 801(d)(2)(e) statements, in the hundreds; held an evidentiary pre-trial hearing about the admissibility of those statements; and made detailed, statement by statement rulings about admissibility, excluding some and conditionally admitting others); United States v. Bozeman, No. 3:11-CR-129, 2012 WL 1071207, at *14 (E.D. Tenn. Mar. 29, 2012), aff'd, No. 3:11-CR-",
      "position": "main body"
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    {
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      "content": "3",
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    {
      "type": "printed",
      "content": "DOJ-OGR-00005964",
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  ],
  "entities": {
    "people": [],
    "organizations": [
      "United States"
    ],
    "locations": [
      "Connecticut",
      "New Mexico",
      "Colorado",
      "Tennessee"
    ],
    "dates": [
      "November 30, 2010",
      "January 24, 2008",
      "March 21, 2018",
      "March 29, 2012",
      "October 29, 2021"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "3:10CR147 JBA",
      "CR 06-2403 RB",
      "15-CR-00073-PAB",
      "3:11-CR-129",
      "398",
      "DOJ-OGR-00005964"
    ]
  },
  "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."
}