mirror-epstein-docs/results/IMAGES003/DOJ-OGR-00006969.json

{
  "document_metadata": {
    "page_number": "7",
    "document_number": "457",
    "date": "11/13/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 457 Filed 11/13/21 Page 7 of 8\nPage 7\nconspiracy. By its very nature, a contact book that collects phone numbers for many people is not the sort of thing that is generated in a single day. Like the digital contact list in the ordinary modern cellphone, a directory represents a collection of information and numbers typically gathered over a period of years. Based on this alone, the jury could readily infer that Government Exhibit 52, which was seen by Employee-1 in , contains information the defendant collected during the period of the conspiracy, including 2004 and earlier. But there is more. As noted, the book contains contact information for .\n\nIn any event, GX-52 is relevant even if it was created after the period of the conspiracy—though, as noted, it clearly was not. Proof that the defendant, at any point in time, had contact information for is relevant to her knowledge of and participation in the crime. Take, for example, a defendant charged with a pattern of bank robberies. If police officers searched the defendant's apartment long after the crimes were committed and discovered a list of the various bank branches the defendant had robbed, there would be no question that the list was relevant, even if it were unclear when the list was made or there was some suggestion that the list was made a year after the robberies. Such a list would reflect the defendant's knowledge of relevant locations, persons, and activities involved in the alleged criminal conduct. This case is no different. No matter when the defendant had this contact information, this evidence demonstrates that the defendant knew .\n\n. Thus, this evidence is directly relevant to the issues before the jury at this trial. See United States v. Abu-Jihaad, 630 F.3d 102, 132 (2d Cir. 2010) (“To be\nDOJ-OGR-00006969",
  "text_blocks": [
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      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 457 Filed 11/13/21 Page 7 of 8",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Page 7",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "conspiracy. By its very nature, a contact book that collects phone numbers for many people is not the sort of thing that is generated in a single day. Like the digital contact list in the ordinary modern cellphone, a directory represents a collection of information and numbers typically gathered over a period of years. Based on this alone, the jury could readily infer that Government Exhibit 52, which was seen by Employee-1 in , contains information the defendant collected during the period of the conspiracy, including 2004 and earlier. But there is more. As noted, the book contains contact information for .\n\nIn any event, GX-52 is relevant even if it was created after the period of the conspiracy—though, as noted, it clearly was not. Proof that the defendant, at any point in time, had contact information for is relevant to her knowledge of and participation in the crime. Take, for example, a defendant charged with a pattern of bank robberies. If police officers searched the defendant's apartment long after the crimes were committed and discovered a list of the various bank branches the defendant had robbed, there would be no question that the list was relevant, even if it were unclear when the list was made or there was some suggestion that the list was made a year after the robberies. Such a list would reflect the defendant's knowledge of relevant locations, persons, and activities involved in the alleged criminal conduct. This case is no different. No matter when the defendant had this contact information, this evidence demonstrates that the defendant knew .\n\n. Thus, this evidence is directly relevant to the issues before the jury at this trial. See United States v. Abu-Jihaad, 630 F.3d 102, 132 (2d Cir. 2010) (“To be",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00006969",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Employee-1",
      "Abu-Jihaad"
    ],
    "organizations": [],
    "locations": [],
    "dates": [
      "11/13/21",
      "2004"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 457",
      "630 F.3d 102",
      "DOJ-OGR-00006969"
    ]
  },
  "additional_notes": "The document appears to be a court filing with redactions. The redactions are likely due to sensitive information being withheld."
}