{
  "document_metadata": {
    "page_number": "23",
    "document_number": "439",
    "date": "11/12/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 439 Filed 11/12/21 Page 23 of 69 B. The Government Has Failed to Carry its Burden to Establish the Extraordinary Need to Use Fake Names The government's motion to use false names and suppress evidence from the public falls short in both evidence and analysis. Other than conclusory arguments by lawyers, the motion contains no facts supporting any of the claims related to future reputational harm or embarrassment. As the proponent of this extraordinary measure, the government cannot simply hypothesize that, as to adult women , the use of false names here will “protect [their] well-being, prevent undue embarrassment and other adverse consequences, including loss of employment, and prevent the victims from being harassed by the press and others.” Mot. at 10. It is the government's burden to establish that, some reason exists to proceed by pseudonym. That “burden is not, of course, discharged by mere conclusory or ipse dixit assertions, for any such rule would foreclose meaningful inquiry” into the issue. In re Bonanno, 344 F.2d 830, 833 (2d Cir. 1965). 15 DOJ-OGR-00006440",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 439 Filed 11/12/21 Page 23 of 69",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "B. The Government Has Failed to Carry its Burden to Establish the Extraordinary Need to Use Fake Names",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The government's motion to use false names and suppress evidence from the public falls short in both evidence and analysis. Other than conclusory arguments by lawyers, the motion contains no facts supporting any of the claims related to future reputational harm or embarrassment. As the proponent of this extraordinary measure, the government cannot simply hypothesize that, as to adult women , the use of false names here will “protect [their] well-being, prevent undue embarrassment and other adverse consequences, including loss of employment, and prevent the victims from being harassed by the press and others.” Mot. at 10. It is the government's burden to establish that, some reason exists to proceed by pseudonym. That “burden is not, of course, discharged by mere conclusory or ipse dixit assertions, for any such rule would foreclose meaningful inquiry” into the issue. In re Bonanno, 344 F.2d 830, 833 (2d Cir. 1965).",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "15",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00006440",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [],
    "organizations": [],
    "locations": [],
    "dates": [
      "11/12/21",
      "1965"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "439",
      "344 F.2d 830",
      "DOJ-OGR-00006440"
    ]
  },
  "additional_notes": "The document contains redactions, likely to protect sensitive information."
}