mirror-epstein-docs/results/IMAGES002/DOJ-OGR-00003720.json

{
  "document_metadata": {
    "page_number": "12",
    "document_number": "208",
    "date": "04/16/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 208 Filed 04/16/21 Page 12 of 16\n\none \"conditions\" questions were all medical in nature. The twenty-second and twenty-third questions, however, inquired about convictions (one about \"traffic convictions,\" the other about \"other convictions\"). Manapat answered in the negative to both question twenty-two and question twenty-three, and these answers became the basis for his prosecution for \"knowingly and willfully\" making false statements to any department or agency of the United States. In affirming the district court's decision to dismiss the indictment, the Eleventh Circuit stated:\n\nAlthough the single statements \"Record of traffic convictions,\" or \"Record of other convictions\" may not be ambiguous standing alone, they become quite confusing when buried in a list headed \"Medical History\" and purportedly concerned with medical conditions.... In order to successfully prosecute an indictment for making a false statement, the government must not remove questions from the context in which their answers were given in an attempt to prove their clarity.\n\nId. at 1101.\n\nAlso helpful is United States v. Chujoy, 207 F. Supp. 3d 626, 654-55 (W.D. Va. 2016), aff'd sub nom. United States v. Edlind, 887 F.3d 166 (4th Cir. 2018), and aff'd, 770 F. App'x 33 (4th Cir. 2019), where the court dismissed multiple perjury and false statement claims, holding:\n\nMoreover, it is not perjurious for [the defendant] to give an evasive answer to a broadly-worded question, so long as her response was not false. See United States v. Reveron Martinez, 836 F.2d 684, 689 (1st Cir. 1988) (\"In order to sustain a perjury charge, evasions are not enough. The government must show more than that the interdicted statement was unresponsive or guarded. At a bare minimum, the remark must have been literally false.\"); United States v. Earp, 812 F.2d 917, 919 (4th Cir. 1987) (\"The burden is on the questioner to pin the witness down to the specific object of the questioner's inquiry.\"); United States v. Naegele, 341 B.R. 349, 359 (D.D.C. 2006) (\"[I]n the context of perjury charges based on adversarial questioning, it is not the declarant's burden to provide candid answers.\"). Accordingly, the government failed to offer sufficient evidence that Edlind's first two answers—that she had dinner with Kwiatkowski in April—were false. No reasonable juror could conclude otherwise.\n\nIn United States v. Ruedlinger, 990 F. Supp. 1295, 1303-04 (D. Kan. 1997), the court after \"carefully review[ing] the allegations\" found that the perjury charge must be dismissed. The",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 208 Filed 04/16/21 Page 12 of 16",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "one \"conditions\" questions were all medical in nature. The twenty-second and twenty-third questions, however, inquired about convictions (one about \"traffic convictions,\" the other about \"other convictions\"). Manapat answered in the negative to both question twenty-two and question twenty-three, and these answers became the basis for his prosecution for \"knowingly and willfully\" making false statements to any department or agency of the United States. In affirming the district court's decision to dismiss the indictment, the Eleventh Circuit stated:",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "Although the single statements \"Record of traffic convictions,\" or \"Record of other convictions\" may not be ambiguous standing alone, they become quite confusing when buried in a list headed \"Medical History\" and purportedly concerned with medical conditions.... In order to successfully prosecute an indictment for making a false statement, the government must not remove questions from the context in which their answers were given in an attempt to prove their clarity.",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "Id. at 1101.",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "Also helpful is United States v. Chujoy, 207 F. Supp. 3d 626, 654-55 (W.D. Va. 2016), aff'd sub nom. United States v. Edlind, 887 F.3d 166 (4th Cir. 2018), and aff'd, 770 F. App'x 33 (4th Cir. 2019), where the court dismissed multiple perjury and false statement claims, holding:",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "Moreover, it is not perjurious for [the defendant] to give an evasive answer to a broadly-worded question, so long as her response was not false. See United States v. Reveron Martinez, 836 F.2d 684, 689 (1st Cir. 1988) (\"In order to sustain a perjury charge, evasions are not enough. The government must show more than that the interdicted statement was unresponsive or guarded. At a bare minimum, the remark must have been literally false.\"); United States v. Earp, 812 F.2d 917, 919 (4th Cir. 1987) (\"The burden is on the questioner to pin the witness down to the specific object of the questioner's inquiry.\"); United States v. Naegele, 341 B.R. 349, 359 (D.D.C. 2006) (\"[I]n the context of perjury charges based on adversarial questioning, it is not the declarant's burden to provide candid answers.\"). Accordingly, the government failed to offer sufficient evidence that Edlind's first two answers—that she had dinner with Kwiatkowski in April—were false. No reasonable juror could conclude otherwise.",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "In United States v. Ruedlinger, 990 F. Supp. 1295, 1303-04 (D. Kan. 1997), the court after \"carefully review[ing] the allegations\" found that the perjury charge must be dismissed. The",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "8",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00003720",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Manapat",
      "Chujoy",
      "Edlind",
      "Reveron Martinez",
      "Earp",
      "Naegele",
      "Kwiatkowski",
      "Ruedlinger"
    ],
    "organizations": [
      "United States"
    ],
    "locations": [
      "Virginia",
      "Kansas"
    ],
    "dates": [
      "04/16/21",
      "2016",
      "2018",
      "2019",
      "1988",
      "1987",
      "2006",
      "1997",
      "April"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "208",
      "207 F. Supp. 3d 626",
      "887 F.3d 166",
      "770 F. App'x 33",
      "836 F.2d 684",
      "812 F.2d 917",
      "341 B.R. 349",
      "990 F. Supp. 1295"
    ]
  },
  "additional_notes": "The document appears to be a court filing discussing perjury and false statement charges. The text is well-formatted and clear, with citations to various court cases."
}