{
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    "page_number": "16",
    "document_number": "311-1",
    "date": "07/02/21",
    "document_type": "court transcript",
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    "has_stamps": true
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  "full_text": "Case 1:20-cr-00330-PAE Document 311-1 Filed 07/02/21 Page 16 of 23\n\nxj3q1gra SEALED\n\n1 sign, which is, you can disclose it without the permission of\n2 the Court if, you know, law enforcement puts a gun to your head\n3 and says produce it. That's not in here.\n4 MR. ROSSMILLER: That's right, your Honor.\n5 THE COURT: I don't know. It's my understanding that\n6 it may have been negotiated out.\n7 MR. ROSSMILLER: It may have been. I will only say\n8 that I believe that -- I'm on less firm ground than in the\n9 cases that we discussed specifically, but I believe that the\n10 converse would be void for public policy; in other words, you\n11 would not be able to put in --\n12 THE COURT: That was my question.\n13 MR. ROSSMILLER: -- you may not disclose this to law\n14 enforcement even given a duly authorized grand jury subpoena.\n15 THE COURT: Thank you for saying the words \"void for\n16 public policy,\" because I was going there. I take it it would\n17 be the government's position that because it would be void as\n18 against public policy to absolutely prohibit the disclosure of\n19 information to law enforcement, that if a party were to say,\n20 \"But I relied on this, that it would not be disclosed to law\n21 enforcement,\" that that would not, in your view, be reasonable\n22 reliance.\n23 MR. ROSSMILLER: Yes, your Honor, I think that's\n24 correct, and I think that that is borne out by the opinion in\n25 Chemical Bank, which essentially says: You should have asked,\n\nSOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 SDNY_GM_00000867 DOJ-OGR-00004909",
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      "content": "Case 1:20-cr-00330-PAE Document 311-1 Filed 07/02/21 Page 16 of 23",
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    {
      "type": "printed",
      "content": "xj3q1gra SEALED",
      "position": "header"
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      "type": "printed",
      "content": "1 sign, which is, you can disclose it without the permission of\n2 the Court if, you know, law enforcement puts a gun to your head\n3 and says produce it. That's not in here.\n4 MR. ROSSMILLER: That's right, your Honor.\n5 THE COURT: I don't know. It's my understanding that\n6 it may have been negotiated out.\n7 MR. ROSSMILLER: It may have been. I will only say\n8 that I believe that -- I'm on less firm ground than in the\n9 cases that we discussed specifically, but I believe that the\n10 converse would be void for public policy; in other words, you\n11 would not be able to put in --\n12 THE COURT: That was my question.\n13 MR. ROSSMILLER: -- you may not disclose this to law\n14 enforcement even given a duly authorized grand jury subpoena.\n15 THE COURT: Thank you for saying the words \"void for\n16 public policy,\" because I was going there. I take it it would\n17 be the government's position that because it would be void as\n18 against public policy to absolutely prohibit the disclosure of\n19 information to law enforcement, that if a party were to say,\n20 \"But I relied on this, that it would not be disclosed to law\n21 enforcement,\" that that would not, in your view, be reasonable\n22 reliance.\n23 MR. ROSSMILLER: Yes, your Honor, I think that's\n24 correct, and I think that that is borne out by the opinion in\n25 Chemical Bank, which essentially says: You should have asked,",
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    {
      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
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    },
    {
      "type": "printed",
      "content": "SDNY_GM_00000867 DOJ-OGR-00004909",
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  ],
  "entities": {
    "people": [
      "ROSSMILLER"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C.",
      "Chemical Bank"
    ],
    "locations": [],
    "dates": [
      "07/02/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "311-1",
      "SDNY_GM_00000867",
      "DOJ-OGR-00004909"
    ]
  },
  "additional_notes": "The document is a court transcript with a 'SEALED' stamp. The conversation is between MR. ROSSMILLER and THE COURT. The document is from the Southern District of New York."
}