{
  "document_metadata": {
    "page_number": "3 of 5",
    "document_number": "451",
    "date": "November 12, 2021",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 451 Filed 11/12/21 Page 3 of 5\n\nInner City Press\n\nNovember 12, 2021\n\nBy E-mail\n\nHon. Alison J. Nathan, United States District Judge\nSouthern District of New York, 40 Foley Square, New York, NY 10007\n\nRe: US v. Maxwell, 20-cr-330 (AJN), second timely opposition to sealing and withholding portions of motions in limine, trial exhibits, public access, docketing\n\nDear Judge Nathan:\n\nOn behalf of Inner City Press and in my personal capacity, I have been covering the above-captioned case. This concerns today's flurry of motions in limine, still replete with redactions.\n\nThis is a Press request that the filings be further unsealed consistent with Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006) and other applicable case law. This is a request that this opposition to sealing be docketed as, for example, took place in US v. Avenatti, 19-cr-374 (JMF), Dkt 85, see https://storage.courtlistener.com/recap/gov.uscourts.nysd.516151/gov.uscourts.nysd.516151.85.0.pdf\n\nThe Government's Justifications for redaction (Docket No. 399, docketed at 10:06 pm on Friday Oct 29) cites Lugosch then says \"The Government also seeks sealing of trial exhibits, which are not public.\" Inner City Press immediately opposed this.\n\nWhile as one example within the US motions of limine, the Government has now redacted the title of its Argument X, footnote 13 and many other phrases are still redacted, as are significant portions of its Exhibit A. Dkt 438 and 438-1.\n\nWorse, the Defendant's response to the US motions in limine has large portions of its table of contents redacted (for example Argument I, A 1, 2 and 3; C 1 and 2, and D).\n\nA full sentence argument in Defendant's submission opposing Doctor Rocchio, who testified earlier this week, is still redacted, see Dkt 443, FN5.\n\nIn Dkt 444 on Page 4, a full paragraph about what the Government has represented that a witness is expected to testify to - and the entirety of Exhibits A and B are still withheld. The same is true of Dkt 445 - both exhibits withheld, and\n\nInner City Press: In-house SDNY: Room 480, 500 Pearl Street, NY NY 10007\nE-mail: Matthew.Lee@innercitypress.com - Tel: 718-716-3540\nRegular Mail: Dag Hammarskjold Center, Box 20047, New York, NY 10017\n\nDOJ-OGR-00006706",
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      "content": "Case 1:20-cr-00330-PAE Document 451 Filed 11/12/21 Page 3 of 5",
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    {
      "type": "printed",
      "content": "Inner City Press\n\nNovember 12, 2021\n\nBy E-mail\n\nHon. Alison J. Nathan, United States District Judge\nSouthern District of New York, 40 Foley Square, New York, NY 10007\n\nRe: US v. Maxwell, 20-cr-330 (AJN), second timely opposition to sealing and withholding portions of motions in limine, trial exhibits, public access, docketing\n\nDear Judge Nathan:",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "On behalf of Inner City Press and in my personal capacity, I have been covering the above-captioned case. This concerns today's flurry of motions in limine, still replete with redactions.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "This is a Press request that the filings be further unsealed consistent with Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006) and other applicable case law. This is a request that this opposition to sealing be docketed as, for example, took place in US v. Avenatti, 19-cr-374 (JMF), Dkt 85, see https://storage.courtlistener.com/recap/gov.uscourts.nysd.516151/gov.uscourts.nysd.516151.85.0.pdf",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The Government's Justifications for redaction (Docket No. 399, docketed at 10:06 pm on Friday Oct 29) cites Lugosch then says \"The Government also seeks sealing of trial exhibits, which are not public.\" Inner City Press immediately opposed this.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "While as one example within the US motions of limine, the Government has now redacted the title of its Argument X, footnote 13 and many other phrases are still redacted, as are significant portions of its Exhibit A. Dkt 438 and 438-1.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Worse, the Defendant's response to the US motions in limine has large portions of its table of contents redacted (for example Argument I, A 1, 2 and 3; C 1 and 2, and D).",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "A full sentence argument in Defendant's submission opposing Doctor Rocchio, who testified earlier this week, is still redacted, see Dkt 443, FN5.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "In Dkt 444 on Page 4, a full paragraph about what the Government has represented that a witness is expected to testify to - and the entirety of Exhibits A and B are still withheld. The same is true of Dkt 445 - both exhibits withheld, and",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Inner City Press: In-house SDNY: Room 480, 500 Pearl Street, NY NY 10007\nE-mail: Matthew.Lee@innercitypress.com - Tel: 718-716-3540\nRegular Mail: Dag Hammarskjold Center, Box 20047, New York, NY 10017",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00006706",
      "position": "footer"
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  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Matthew Lee"
    ],
    "organizations": [
      "Inner City Press",
      "Southern District of New York",
      "US Government"
    ],
    "locations": [
      "New York"
    ],
    "dates": [
      "November 12, 2021",
      "October 29"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "20-cr-330",
      "19-cr-374",
      "451",
      "399",
      "438",
      "438-1",
      "443",
      "444",
      "445",
      "85"
    ]
  },
  "additional_notes": "The document is a letter from Inner City Press to Judge Alison J. Nathan regarding the case US v. Maxwell. The letter discusses the redactions in the motions in limine and trial exhibits, and requests that the filings be further unsealed."
}