mirror-epstein-docs/results/IMAGES002/DOJ-OGR-00003135.json

{
  "document_metadata": {
    "page_number": "201",
    "document_number": "204",
    "date": "04/16/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 201 of 239\n355 (\"It is well established that '[w]hether to prosecute and what charge to file or bring before a grand jury are decisions that generally rest in the prosecutor's discretion,' and 'a defendant has no constitutional right to elect which of two applicable federal statutes shall be the basis of his indictment and prosecution . . .'\" (brackets and ellipses in original) (quoting United States v. Batchelder, 442 U.S. 114, 124 (1979))).\nOnly after the Court has heard all of the evidence at trial and received the jury's verdict will the defense motion be ripe. Accordingly, the motion should be denied as premature.\nX. The Defendant's Various Disclosure Motions Should be Denied\nMaxwell's motions also include an assortment of requests for orders requiring the Government to make various disclosures, all of which are meritless or, at best, premature.\nA. Bill of Particulars Is Not Warranted\nFirst, the defendant moves for a bill of particulars, demanding the Government set out an array of details regarding the Government's theory of its case and anticipated witness testimony.\nThe defendant, like all defendants, is entitled to sufficient information to understand the charges against her, to prepare a defense, and to protect against double jeopardy. However, the Government has provided such information, and much more, in the Indictment, extensive discovery, and various pretrial filings, including this memorandum. The defendant will also receive trial exhibits, a witness list, and Jencks Act material reasonably in advance of trial. As such, she has not established an entitlement to a bill of particulars under well-established governing law.\n1. Applicable Law\nThe proper purpose of a bill of particulars under Federal Rule of Criminal Procedure 7(f) is \"to provide defendant with information about the details of the charge against him if this is\n174\nDOJ-OGR-00003135",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 201 of 239",
      "position": "header"
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    {
      "type": "printed",
      "content": "355 (\"It is well established that '[w]hether to prosecute and what charge to file or bring before a grand jury are decisions that generally rest in the prosecutor's discretion,' and 'a defendant has no constitutional right to elect which of two applicable federal statutes shall be the basis of his indictment and prosecution . . .'\" (brackets and ellipses in original) (quoting United States v. Batchelder, 442 U.S. 114, 124 (1979))).\nOnly after the Court has heard all of the evidence at trial and received the jury's verdict will the defense motion be ripe. Accordingly, the motion should be denied as premature.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "X. The Defendant's Various Disclosure Motions Should be Denied",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Maxwell's motions also include an assortment of requests for orders requiring the Government to make various disclosures, all of which are meritless or, at best, premature.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "A. Bill of Particulars Is Not Warranted",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "First, the defendant moves for a bill of particulars, demanding the Government set out an array of details regarding the Government's theory of its case and anticipated witness testimony.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The defendant, like all defendants, is entitled to sufficient information to understand the charges against her, to prepare a defense, and to protect against double jeopardy. However, the Government has provided such information, and much more, in the Indictment, extensive discovery, and various pretrial filings, including this memorandum. The defendant will also receive trial exhibits, a witness list, and Jencks Act material reasonably in advance of trial. As such, she has not established an entitlement to a bill of particulars under well-established governing law.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "1. Applicable Law",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The proper purpose of a bill of particulars under Federal Rule of Criminal Procedure 7(f) is \"to provide defendant with information about the details of the charge against him if this is",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "174",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00003135",
      "position": "footer"
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  ],
  "entities": {
    "people": [
      "Maxwell"
    ],
    "organizations": [
      "Government",
      "Court"
    ],
    "locations": [],
    "dates": [
      "04/16/21",
      "1979"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 204",
      "442 U.S. 114"
    ]
  },
  "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."
}