mirror-epstein-docs/results/IMAGES002/DOJ-OGR-00003121.json

{
  "document_metadata": {
    "page_number": "187",
    "document_number": "204",
    "date": "04/16/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
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  "full_text": "Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 187 of 239\n\nMurgio, 209 F. Supp. 3d at 724 (internal quotation marks omitted) (quoting United States v. Smith, 985 F. Supp. 2d 547, 610 (S.D.N.Y. 2014)).\n\nIn setting forth allegations in an indictment, the Government is not limited to description of only the bare elements of a crime; rather, an indictment may be used to provide background to the charged criminal conduct, to describe the circumstances, means, and methods of an offense, and to describe evidence that is otherwise admissible at trial. Simply put, \"[s]tatements providing background are relevant and need not be struck.\" United States v. Mostafa, 965 F. Supp. 2d 451, 466 (S.D.N.Y. 2013) (citing Mulder, 273 F.3d at 100). Allegations also will not be stricken where they elucidate the circumstances, means, and methods of a charged scheme or would be admissible, in the alternative, under Rule 404(b) of the Federal Rules of Evidence. See United States v. Hernandez, 85 F.3d 1023, 1030 (2d Cir. 1996) (affirming denial of motion to strike surplusage where \"[d]efendants' cocaine-related activity was clearly relevant evidence of the organizational structure and method of operation of their heroin conspiracy, and it also tended to establish the nature of the relationship between Defendants and their supplier of heroin, defendant Jose Antonio Hernandez,\" and citing Rule 404(b)).\n\nIn terms of timing, \"[c]ourts in this district routinely await presentation of the Government's evidence at trial before ruling on a motion to strike.\" Mostafa, 965 F. Supp. 2d at 467 (citing, inter alia, Scarpa, 913 F.2d at 1012); see also United States v. Ahmed, No. 10 Cr. 131 (PKC), 2011 WL 5041456, at *3 (S.D.N.Y. Oct. 21, 2011). As multiple courts have concluded, \"[t]here is little or no purpose in attempting to predict in advance of trial what evidence will prove admissible or how specific allegations relate to the overall charges.\" Smith, 985 F. Supp. 2d at 612 (brackets in original) (quoting United States v. Butler, 351 F. Supp. 121, 124 (S.D.N.Y. 2004)).\n\n160\n\nDOJ-OGR-00003121",
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      "content": "Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 187 of 239",
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      "content": "Murgio, 209 F. Supp. 3d at 724 (internal quotation marks omitted) (quoting United States v. Smith, 985 F. Supp. 2d 547, 610 (S.D.N.Y. 2014)).",
      "position": "top"
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    {
      "type": "printed",
      "content": "In setting forth allegations in an indictment, the Government is not limited to description of only the bare elements of a crime; rather, an indictment may be used to provide background to the charged criminal conduct, to describe the circumstances, means, and methods of an offense, and to describe evidence that is otherwise admissible at trial. Simply put, \"[s]tatements providing background are relevant and need not be struck.\" United States v. Mostafa, 965 F. Supp. 2d 451, 466 (S.D.N.Y. 2013) (citing Mulder, 273 F.3d at 100). Allegations also will not be stricken where they elucidate the circumstances, means, and methods of a charged scheme or would be admissible, in the alternative, under Rule 404(b) of the Federal Rules of Evidence. See United States v. Hernandez, 85 F.3d 1023, 1030 (2d Cir. 1996) (affirming denial of motion to strike surplusage where \"[d]efendants' cocaine-related activity was clearly relevant evidence of the organizational structure and method of operation of their heroin conspiracy, and it also tended to establish the nature of the relationship between Defendants and their supplier of heroin, defendant Jose Antonio Hernandez,\" and citing Rule 404(b)).",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "In terms of timing, \"[c]ourts in this district routinely await presentation of the Government's evidence at trial before ruling on a motion to strike.\" Mostafa, 965 F. Supp. 2d at 467 (citing, inter alia, Scarpa, 913 F.2d at 1012); see also United States v. Ahmed, No. 10 Cr. 131 (PKC), 2011 WL 5041456, at *3 (S.D.N.Y. Oct. 21, 2011). As multiple courts have concluded, \"[t]here is little or no purpose in attempting to predict in advance of trial what evidence will prove admissible or how specific allegations relate to the overall charges.\" Smith, 985 F. Supp. 2d at 612 (brackets in original) (quoting United States v. Butler, 351 F. Supp. 121, 124 (S.D.N.Y. 2004)).",
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      "type": "printed",
      "content": "160",
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      "type": "printed",
      "content": "DOJ-OGR-00003121",
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  "entities": {
    "people": [
      "Murgio",
      "Smith",
      "Mostafa",
      "Mulder",
      "Hernandez",
      "Jose Antonio Hernandez",
      "Scarpa",
      "Ahmed",
      "Butler"
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    "organizations": [
      "Government",
      "Federal Rules of Evidence"
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    "locations": [
      "S.D.N.Y.",
      "2d Cir."
    ],
    "dates": [
      "04/16/21",
      "2014",
      "2013",
      "1996",
      "Oct. 21, 2011",
      "2004"
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    "reference_numbers": [
      "Case 1:20-cr-00330-PAE",
      "Document 204",
      "No. 10 Cr. 131 (PKC)"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is mostly printed, with no handwritten content or stamps visible. The document is well-formatted and legible."
}