{
  "document_metadata": {
    "page_number": "19",
    "document_number": "440",
    "date": "11/12/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "to make the point. She does not. Much of this information can be elicited without using names at all, such as Minor Victim-4's past statements and the general arc of the Minor Victims' professional work.10 And the defense does not provide a particularized justification for any identifying information, . Even the baseless defense argument that Minor Victim-4 and her lawyer are suborning perjury would not require use of either name. Notably, despite the numerous cases in which pseudonyms or first names have been used, the defense cites no case in which a court has forced victims to testify under their true names so that the defense could conduct cross-examination along these lines. The defendant also argues that \"[s]ubstantial impeachment evidence exists as to [Minor Victim-4] under her real name,\" and the defendant \"should not be forced to compromise the full effect of this evidence by use of a first name only.\" (Def. Opp. at 22). The defendant is not so compromised. The defendant is allowed to elicit this information and, where it is contained in exhibits, and show those to the jury without redaction. The jury will know the Minor Victims' full names and will understand the complete argument. The defense can even say Minor Victim-4's first name. They would only be limited from saying her last name out loud in court. The same is true with exhibits including the names of certain other Minor Victims.11",
  "text_blocks": [
    {
      "type": "printed",
      "content": "to make the point. She does not. Much of this information can be elicited without using names at all, such as Minor Victim-4's past statements and the general arc of the Minor Victims' professional work.10 And the defense does not provide a particularized justification for any identifying information, . Even the baseless defense argument that Minor Victim-4 and her lawyer are suborning perjury would not require use of either name. Notably, despite the numerous cases in which pseudonyms or first names have been used, the defense cites no case in which a court has forced victims to testify under their true names so that the defense could conduct cross-examination along these lines.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The defendant also argues that \"[s]ubstantial impeachment evidence exists as to [Minor Victim-4] under her real name,\" and the defendant \"should not be forced to compromise the full effect of this evidence by use of a first name only.\" (Def. Opp. at 22). The defendant is not so compromised. The defendant is allowed to elicit this information and, where it is contained in exhibits, and show those to the jury without redaction. The jury will know the Minor Victims' full names and will understand the complete argument. The defense can even say Minor Victim-4's first name. They would only be limited from saying her last name out loud in court. The same is true with exhibits including the names of certain other Minor Victims.11",
      "position": "middle"
    },
    {
      "type": "other",
      "content": "18",
      "position": "bottom"
    },
    {
      "type": "other",
      "content": "DOJ-OGR-00006535",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Minor Victim-4"
    ],
    "organizations": [],
    "locations": [],
    "dates": [
      "11/12/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "440",
      "22",
      "10",
      "11",
      "DOJ-OGR-00006535"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. The text discusses the use of pseudonyms or first names for minor victims and the defendant's argument regarding impeachment evidence. There are redactions in the text, indicated by blacked-out sections."
}