mirror-epstein-docs/results/IMAGES002/DOJ-OGR-00003151.json

{
  "document_metadata": {
    "page_number": "217",
    "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 217 of 239\nthe court and defense counsel that it recognizes and has complied with its disclosure obligations under Brady,' defendants' request for immediate or otherwise early production of Brady materials is denied.\" (internal citation omitted) (quoting United States v. Perez, 940 F. Supp. 540, 553 (S.D.N.Y.1996)); Gallo, 1999 WL 9848, at *8 (denying defendant's motion to compel production of purported Brady material based on Government's representations that \"it is aware of its obligations under Brady . . . and will produce any Brady material to the defense well before trial\"); United States v. Campo Flores, No. 15 Cr. 765 (PAC), 2016 WL 5946472, at *11 (S.D.N.Y. Oct. 12, 2016) (\"The Government represents that it is aware of its obligation under Brady; that it has complied; and will continue to comply. That is sufficient to deny Defendants' motion for Brady relief.\") (internal citations omitted)). Given the Government's extensive efforts to review its files for any material warranting disclosure, and its commitment to continue meeting its disclosure obligations, the motion should be denied.\nFor similar reasons, the motion for disclosure of Giglio material should be denied as premature. The Government is fully aware of its obligation to disclose impeachment material, is in the process of reviewing all files in its possession for any such material, and will produce any such material several weeks in advance of trial. As noted above, that is consistent with governing law in this Circuit, and the defendant cites no authority for the proposition that she is entitled to such material as much as four months in advance of trial. Courts in this Circuit have repeatedly refused to compel disclosure of impeachment or Giglio material well in advance of trial, and the defense has provided no particularized basis for even earlier disclosure here. See United States v. Nixon, 418 U.S. 683, 701 (1974) (\"Generally, the need for evidence to impeach witnesses is insufficient to require its production in advance of trial.\"); Campo Flores, 2016 WL 5946472, at *11 (\"The Government has represented that it will make impeachment material relating to its 190 DOJ-OGR-00003151",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 217 of 239",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "the court and defense counsel that it recognizes and has complied with its disclosure obligations under Brady,' defendants' request for immediate or otherwise early production of Brady materials is denied.\" (internal citation omitted) (quoting United States v. Perez, 940 F. Supp. 540, 553 (S.D.N.Y.1996)); Gallo, 1999 WL 9848, at *8 (denying defendant's motion to compel production of purported Brady material based on Government's representations that \"it is aware of its obligations under Brady . . . and will produce any Brady material to the defense well before trial\"); United States v. Campo Flores, No. 15 Cr. 765 (PAC), 2016 WL 5946472, at *11 (S.D.N.Y. Oct. 12, 2016) (\"The Government represents that it is aware of its obligation under Brady; that it has complied; and will continue to comply. That is sufficient to deny Defendants' motion for Brady relief.\") (internal citations omitted)). Given the Government's extensive efforts to review its files for any material warranting disclosure, and its commitment to continue meeting its disclosure obligations, the motion should be denied.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "For similar reasons, the motion for disclosure of Giglio material should be denied as premature. The Government is fully aware of its obligation to disclose impeachment material, is in the process of reviewing all files in its possession for any such material, and will produce any such material several weeks in advance of trial. As noted above, that is consistent with governing law in this Circuit, and the defendant cites no authority for the proposition that she is entitled to such material as much as four months in advance of trial. Courts in this Circuit have repeatedly refused to compel disclosure of impeachment or Giglio material well in advance of trial, and the defense has provided no particularized basis for even earlier disclosure here. See United States v. Nixon, 418 U.S. 683, 701 (1974) (\"Generally, the need for evidence to impeach witnesses is insufficient to require its production in advance of trial.\"); Campo Flores, 2016 WL 5946472, at *11 (\"The Government has represented that it will make impeachment material relating to its",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "190",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00003151",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Nixon"
    ],
    "organizations": [
      "United States",
      "Government",
      "Court",
      "Defense"
    ],
    "locations": [
      "S.D.N.Y."
    ],
    "dates": [
      "04/16/21",
      "Oct. 12, 2016",
      "1974"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 204",
      "15 Cr. 765 (PAC)",
      "2016 WL 5946472",
      "418 U.S. 683",
      "DOJ-OGR-00003151"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case, discussing the disclosure of Brady and Giglio materials. The text is printed and there are no visible stamps or handwritten notes. The document is from the United States District Court for the Southern District of New York."
}