{
  "document_metadata": {
    "page_number": "15",
    "document_number": "311-1",
    "date": "07/02/21",
    "document_type": "court transcript",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 311-1 Filed 07/02/21 Page 15 of 23\n\nxj3q1gra\n\nSEALED\n\n1 THE COURT: Could I see what you provided Judge Sweet.\n2 MR. ROSSMILLER: Yes, of course.\n3 And your Honor, just for the record, I'm handing over what was our initial sealed affirmation and application to the Court for an order under the All Writs Act, and that includes an affirmation and application that I signed with an exhibit attached of the original protective order, followed by which is a proposed order for entry by Judge Sweet, which we of course would be happy to submit to the Court in Word form or in revised form, subject to the Court's views.\n4 THE COURT: Right. I just wanted to see if it had a certain provision.\n5 MR. ROSSMILLER: If there is a provision that the Court thinks would address some of these issues, we would of course be happy to hear it.\n6 THE COURT: Of course I'm not Judge Sweet, so I don't know exactly what was going on in his head.\n7 I assume it would be the government's position that reliance on the nondisclosure of confidential materials to law enforcement in connection with a grand jury subpoena that has been duly authorized would be unreasonable. It wouldn't be reasonable reliance to assume that the protective order could never be modified to allow -- I mean, the parties to this negotiated the protective order, and the protective order does not contain the provision that is in every protective order I\n\nSOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 SDNY_GM_00000866 DOJ-OGR-00004908",
  "text_blocks": [
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      "content": "Case 1:20-cr-00330-PAE Document 311-1 Filed 07/02/21 Page 15 of 23",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "xj3q1gra\n\nSEALED",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "1 THE COURT: Could I see what you provided Judge Sweet.\n2 MR. ROSSMILLER: Yes, of course.\n3 And your Honor, just for the record, I'm handing over what was our initial sealed affirmation and application to the Court for an order under the All Writs Act, and that includes an affirmation and application that I signed with an exhibit attached of the original protective order, followed by which is a proposed order for entry by Judge Sweet, which we of course would be happy to submit to the Court in Word form or in revised form, subject to the Court's views.\n4 THE COURT: Right. I just wanted to see if it had a certain provision.\n5 MR. ROSSMILLER: If there is a provision that the Court thinks would address some of these issues, we would of course be happy to hear it.\n6 THE COURT: Of course I'm not Judge Sweet, so I don't know exactly what was going on in his head.\n7 I assume it would be the government's position that reliance on the nondisclosure of confidential materials to law enforcement in connection with a grand jury subpoena that has been duly authorized would be unreasonable. It wouldn't be reasonable reliance to assume that the protective order could never be modified to allow -- I mean, the parties to this negotiated the protective order, and the protective order does not contain the provision that is in every protective order I",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 SDNY_GM_00000866 DOJ-OGR-00004908",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Judge Sweet",
      "MR. ROSSMILLER"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [],
    "dates": [
      "07/02/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "311-1",
      "SDNY_GM_00000866",
      "DOJ-OGR-00004908",
      "(212) 805-0300"
    ]
  },
  "additional_notes": "The document appears to be a court transcript with a header indicating it is sealed. The content discusses a protective order and a grand jury subpoena. The footer contains information about the court reporter and reference numbers."
}