mirror-epstein-docs/results/IMAGES004/DOJ-OGR-00011302.json

{
  "document_metadata": {
    "page_number": "3",
    "document_number": "713",
    "date": "07/12/22",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 713 Filed 07/12/22 Page 3 of 4\n\nthat the district court abused its discretion in denying a continuance to permit the witness to be brought to trial.\" Id.; see also Untied States v. DeCologero, 530 F.3d 36, 74 (1st Cir. 2008) (collecting cases and granting a motion to transport but refusing to order the Marshals to expedite it and denying a continuance because the request was \"quite belated[]\").\n\nAdditionally, Bovino's testimony is in no way vital. The defendant articulated a theory of relevance in her opposition to the Government's motion to preclude, and it is the same theory that the defendant articulated as to two other witnesses. The defendant will suffer no significant prejudice by denial of her motion.\n\nFinally, what the defendant posits is no mere delay until Monday. What the defendant suggests is to direct the Marshals Service to arrest a defendant located in California, detain her, fly her across the country, and possibly arrange counsel for her, all so that she may provide a few minutes of testimony. Under the unique facts of this case—a lengthy trial in the middle of a global pandemic, with looming extended breaks for two holidays—an arrest warrant would likely cause significant delay and risk to the trial. The defendant's eleventh-hour request for such an extended delay is not justified under these circumstances.\n\n3\nDOJ-OGR-00011302",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 713 Filed 07/12/22 Page 3 of 4",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "that the district court abused its discretion in denying a continuance to permit the witness to be brought to trial.\" Id.; see also Untied States v. DeCologero, 530 F.3d 36, 74 (1st Cir. 2008) (collecting cases and granting a motion to transport but refusing to order the Marshals to expedite it and denying a continuance because the request was \"quite belated[]\").",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Additionally, Bovino's testimony is in no way vital. The defendant articulated a theory of relevance in her opposition to the Government's motion to preclude, and it is the same theory that the defendant articulated as to two other witnesses. The defendant will suffer no significant prejudice by denial of her motion.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Finally, what the defendant posits is no mere delay until Monday. What the defendant suggests is to direct the Marshals Service to arrest a defendant located in California, detain her, fly her across the country, and possibly arrange counsel for her, all so that she may provide a few minutes of testimony. Under the unique facts of this case—a lengthy trial in the middle of a global pandemic, with looming extended breaks for two holidays—an arrest warrant would likely cause significant delay and risk to the trial. The defendant's eleventh-hour request for such an extended delay is not justified under these circumstances.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "3",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00011302",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [],
    "organizations": [
      "Government",
      "Marshals Service"
    ],
    "locations": [
      "California"
    ],
    "dates": [
      "07/12/22",
      "Monday"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 713",
      "530 F.3d 36",
      "DOJ-OGR-00011302"
    ]
  },
  "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 3 of 4."
}