mirror-epstein-docs/results/IMAGES003/DOJ-OGR-00006769.json

{
  "document_metadata": {
    "page_number": "61",
    "document_number": "452",
    "date": "11/12/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 452 Filed 11/12/21 Page 61 of 84\n\nas the defense might like the Government to create such an index, that is simply not how the litigation of co-conspirator statements is handled. And it is not what the Court's order, requiring \"disclos[ur]e\" of co-conspirator statements, required.\n\nThe Government's obligation is to make disclosures. The Government is not obligated to serve as members of the defense team, reviewing Jencks Act materials for the defense and itemizing and indexing disclosures for them. The Government is no more obligated to itemize Jencks Act materials containing co-conspirator statements than it is obligated to exhaustively detail for the defense the basis for offering any other type of witness statement contained in the Jencks Act material it has produced. Such an obligation would extremely burdensome and is both without precedent and entirely unnecessary. The defense team has ample resources to review the Government's disclosures and file any motions they wish to make regarding the admission of certain testimony. And there is ample time before trial for the defense to do so, and no basis in the record to believe the defense will be unable to raise these issues and seek a ruling before trial.\n\nThe defense argues that the Court did order the Government to itemize co-conspirator statements contained in its Jencks Act production. In support, however, the defense cites to orders relating to the disclosure of the identities of co-conspirators. (Compare Def. Mot. 1 at 2 (citing Dkt. No. 317 at 12 n.1) and Def. Mot. 1 at 3 (citing Dkt. No. 335 at 3) (stating that the Court rejected the defendant's arguments \"because of 'the need for the parties to litigate co-conspirator issues in advance of trial'\" (emphasis in Def. Mot. 1)), with Op. & Order at 12 n.1, Dkt. No. 317 (\"Additionally, Maxwell includes in her motion for a bill of particulars a request to require the government to identify the unnamed co-conspirators who allegedly participated in the conspiracies\n\n60\n\nDOJ-OGR-00006769",
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      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 452 Filed 11/12/21 Page 61 of 84",
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    {
      "type": "printed",
      "content": "as the defense might like the Government to create such an index, that is simply not how the litigation of co-conspirator statements is handled. And it is not what the Court's order, requiring \"disclos[ur]e\" of co-conspirator statements, required.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The Government's obligation is to make disclosures. The Government is not obligated to serve as members of the defense team, reviewing Jencks Act materials for the defense and itemizing and indexing disclosures for them. The Government is no more obligated to itemize Jencks Act materials containing co-conspirator statements than it is obligated to exhaustively detail for the defense the basis for offering any other type of witness statement contained in the Jencks Act material it has produced. Such an obligation would extremely burdensome and is both without precedent and entirely unnecessary. The defense team has ample resources to review the Government's disclosures and file any motions they wish to make regarding the admission of certain testimony. And there is ample time before trial for the defense to do so, and no basis in the record to believe the defense will be unable to raise these issues and seek a ruling before trial.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The defense argues that the Court did order the Government to itemize co-conspirator statements contained in its Jencks Act production. In support, however, the defense cites to orders relating to the disclosure of the identities of co-conspirators. (Compare Def. Mot. 1 at 2 (citing Dkt. No. 317 at 12 n.1) and Def. Mot. 1 at 3 (citing Dkt. No. 335 at 3) (stating that the Court rejected the defendant's arguments \"because of 'the need for the parties to litigate co-conspirator issues in advance of trial'\" (emphasis in Def. Mot. 1)), with Op. & Order at 12 n.1, Dkt. No. 317 (\"Additionally, Maxwell includes in her motion for a bill of particulars a request to require the government to identify the unnamed co-conspirators who allegedly participated in the conspiracies",
      "position": "middle"
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    {
      "type": "printed",
      "content": "60",
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    {
      "type": "printed",
      "content": "DOJ-OGR-00006769",
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  "entities": {
    "people": [
      "Maxwell"
    ],
    "organizations": [
      "Government",
      "Court"
    ],
    "locations": [],
    "dates": [
      "11/12/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "452",
      "317",
      "335",
      "DOJ-OGR-00006769"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is printed and there are no visible stamps or handwritten notes. The document is page 61 of 84."
}