mirror-epstein-docs/results/IMAGES004/DOJ-OGR-00009495.json

{
  "document_metadata": {
    "page_number": "78",
    "document_number": "6163/20",
    "date": "08/24/22",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00336-PAE Document 6163/20 Filed 08/24/22 Page 78 of 117\nA-5919\n\nCAC3PARC 17\n1 they had. Your Honor, that in our view ends the inquiry\n2 completely. That finding alone is sufficient to defeat a\n3 finding of ineffective assistance of counsel.\n4 The Second Circuit has made very clear, as have other\n5 circuits, that you cannot as a defense counsel basically engage\n6 in a heads-we-win-tails-you-lose strategy when it comes to your\n7 trial conduct. We know that based on the documentary evidence\n8 and the evidence that was adduced at the hearing as well as the\n9 evidence that was put forth in the affidavit of Susan Brune,\n10 that the Brune & Richard law firm had the suspension opinion\n11 prior to voir dire, and chose not to bring it to this Court's\n12 attention. As we all know engaged in subsequent investigation\n13 regarding Juror No. 1, when Theresa Trzskoma started to have\n14 certain doubts about her after the receipt of Juror No. 1's\n15 note.\n16 It's quite clear that this is not a case where the\n17 defense counsel had been given a piece of information and did\n18 nothing. That's quite, quite not what happened here. In fact,\n19 we know that prior to voir dire, they discussed the suspension\n20 opinion, they chose not to bring it to the Court's attention.\n21 Instead relying simply on the voir dire answers, even though as\n22 this Court pointed out, far more trivial issues were aired by\n23 all of the parties, by the government and indeed by the Court,\n24 in terms of trying to figure out who would be good jurors.\n25 They chose not to bring that to the Court's attention then\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nDOJ-OGR-00009495",
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      "type": "printed",
      "content": "Case 1:20-cr-00336-PAE Document 6163/20 Filed 08/24/22 Page 78 of 117",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "A-5919",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "CAC3PARC 17\n1 they had. Your Honor, that in our view ends the inquiry\n2 completely. That finding alone is sufficient to defeat a\n3 finding of ineffective assistance of counsel.\n4 The Second Circuit has made very clear, as have other\n5 circuits, that you cannot as a defense counsel basically engage\n6 in a heads-we-win-tails-you-lose strategy when it comes to your\n7 trial conduct. We know that based on the documentary evidence\n8 and the evidence that was adduced at the hearing as well as the\n9 evidence that was put forth in the affidavit of Susan Brune,\n10 that the Brune & Richard law firm had the suspension opinion\n11 prior to voir dire, and chose not to bring it to this Court's\n12 attention. As we all know engaged in subsequent investigation\n13 regarding Juror No. 1, when Theresa Trzskoma started to have\n14 certain doubts about her after the receipt of Juror No. 1's\n15 note.\n16 It's quite clear that this is not a case where the\n17 defense counsel had been given a piece of information and did\n18 nothing. That's quite, quite not what happened here. In fact,\n19 we know that prior to voir dire, they discussed the suspension\n20 opinion, they chose not to bring it to the Court's attention.\n21 Instead relying simply on the voir dire answers, even though as\n22 this Court pointed out, far more trivial issues were aired by\n23 all of the parties, by the government and indeed by the Court,\n24 in terms of trying to figure out who would be good jurors.\n25 They chose not to bring that to the Court's attention then",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00009495",
      "position": "footer"
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  ],
  "entities": {
    "people": [
      "Susan Brune",
      "Theresa Trzskoma"
    ],
    "organizations": [
      "Brune & Richard law firm",
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [],
    "dates": [
      "08/24/22"
    ],
    "reference_numbers": [
      "1:20-cr-00336-PAE",
      "6163/20",
      "A-5919",
      "DOJ-OGR-00009495"
    ]
  },
  "additional_notes": "The document appears to be a court transcript or legal document. The text is mostly printed, with no visible handwriting or stamps. The document is well-formatted and easy to read."
}