{
  "document_metadata": {
    "page_number": "2",
    "document_number": "455",
    "date": "11/12/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 455 Filed 11/12/21 Page 2 of 3 Page 2 (11/01/21 Tr. at 10:8-11). That information has no impeachment value—. But it creates significant risk of identifying the relevant Minor Victims and witnesses by narrowing the field of people whose careers match the description elicited by the defence at the times elicited by the defense, and in combination with the other information about them that will be available at trial. Second, the Government seeks clarification that the Court's November 1, 2021 order permitting witnesses to testify using pseudonyms or first names includes an order barring courtroom sketch artists from drawing the exact likeness of those individuals. (See Gov't Mot. in Limine, Dkt. No. 380, at 16 n.7 (making this request)); see May 6, 2019 Text Order, Raniere, 18 Cr. 204 (NGG) (E.D.N.Y.) (“Sketch artists . . . may not draw exact likenesses of jurors or witnesses other than co-defendants should they testify . . . .”). It would defeat the purpose of the Court's order if the exact likeness of those witnesses could be drawn and subsequently publicized in the media. Although courtroom sketch artists might voluntarily elect not to sketch these witness's faces, the Government seeks an order so it can provide certainty to these witnesses in advance of their testimony. 1 The Government's proposed redactions are consistent with the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Although this letter is a judicial document subject to the common law presumption of access, the proposed redactions are narrowly tailored to protect the privacy interests of the witnesses whom the Court has authorized to testify using pseudonyms or their first names. DOJ-OGR-00006951",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 455 Filed 11/12/21 Page 2 of 3",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Page 2",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "(11/01/21 Tr. at 10:8-11). That information has no impeachment value—. But it creates significant risk of identifying the relevant Minor Victims and witnesses by narrowing the field of people whose careers match the description elicited by the defence at the times elicited by the defense, and in combination with the other information about them that will be available at trial. Second, the Government seeks clarification that the Court's November 1, 2021 order permitting witnesses to testify using pseudonyms or first names includes an order barring courtroom sketch artists from drawing the exact likeness of those individuals. (See Gov't Mot. in Limine, Dkt. No. 380, at 16 n.7 (making this request)); see May 6, 2019 Text Order, Raniere, 18 Cr. 204 (NGG) (E.D.N.Y.) (“Sketch artists . . . may not draw exact likenesses of jurors or witnesses other than co-defendants should they testify . . . .”). It would defeat the purpose of the Court's order if the exact likeness of those witnesses could be drawn and subsequently publicized in the media. Although courtroom sketch artists might voluntarily elect not to sketch these witness's faces, the Government seeks an order so it can provide certainty to these witnesses in advance of their testimony.",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "1 The Government's proposed redactions are consistent with the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Although this letter is a judicial document subject to the common law presumption of access, the proposed redactions are narrowly tailored to protect the privacy interests of the witnesses whom the Court has authorized to testify using pseudonyms or their first names.",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00006951",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [],
    "organizations": [
      "Government",
      "Court",
      "Second Circuit"
    ],
    "locations": [
      "E.D.N.Y."
    ],
    "dates": [
      "11/01/21",
      "November 1, 2021",
      "May 6, 2019",
      "11/12/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 455",
      "Dkt. No. 380",
      "18 Cr. 204 (NGG)",
      "435 F.3d 110",
      "DOJ-OGR-00006951"
    ]
  },
  "additional_notes": "The document appears to be a court filing with redactions to protect witness privacy. The text is mostly printed, with no handwritten content or stamps visible."
}