{
  "document_metadata": {
    "page_number": "3",
    "document_number": "415",
    "date": "11/04/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 415 Filed 11/04/21 Page 3 of 3\nPage 3\nof the names and occupations of prospective jurors no more than five days before trial. (Dkt. No. 407, Def. Ex. A). In United States v. Daugerdas, 450 prospective jurors completed a basic hardship questionnaire; the court excused a number of prospective jurors who had claimed hardships on their questionnaires; the court conducted three-day voir dire; the parties exercised peremptory challenges; and trial commenced. 867 F. Supp. 2d 445, 449-51 (S.D.N.Y. 2012). Through the jury selection process, one juror “lied extensively during voir dire and concealed important information about her background.” Id. at 451. That one juror “lied extensively” during voir dire in Daugerdas does not provide a basis for the relief sought here. Neither Kessler nor Daugerdas stands for the proposition that a defendant has a constitutional right to conduct outside research on jurors, much less that a certain amount of time is required to do so. The Court has indicated that it would ensure a fair jury is selected, and the Court has carefully crafted a juror questionnaire and voir dire process with input from the parties on the questions asked of prospective jurors. This process will ensure that a fair jury is empaneled. The defendant’s motion for reconsideration should be denied. Respectfully submitted, DAMIAN WILLIAMS United States Attorney By: s/ Alison Moe Lara Pomerantz Andrew Rohrbach Assistant United States Attorneys Southern District of New York Cc: Defense Counsel (By ECF) DOJ-OGR-00006174",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 415 Filed 11/04/21 Page 3 of 3",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Page 3",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "of the names and occupations of prospective jurors no more than five days before trial. (Dkt. No. 407, Def. Ex. A). In United States v. Daugerdas, 450 prospective jurors completed a basic hardship questionnaire; the court excused a number of prospective jurors who had claimed hardships on their questionnaires; the court conducted three-day voir dire; the parties exercised peremptory challenges; and trial commenced. 867 F. Supp. 2d 445, 449-51 (S.D.N.Y. 2012). Through the jury selection process, one juror “lied extensively during voir dire and concealed important information about her background.” Id. at 451. That one juror “lied extensively” during voir dire in Daugerdas does not provide a basis for the relief sought here. Neither Kessler nor Daugerdas stands for the proposition that a defendant has a constitutional right to conduct outside research on jurors, much less that a certain amount of time is required to do so. The Court has indicated that it would ensure a fair jury is selected, and the Court has carefully crafted a juror questionnaire and voir dire process with input from the parties on the questions asked of prospective jurors. This process will ensure that a fair jury is empaneled. The defendant’s motion for reconsideration should be denied.",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "Respectfully submitted,",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "DAMIAN WILLIAMS United States Attorney",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "By: s/ Alison Moe Lara Pomerantz Andrew Rohrbach Assistant United States Attorneys Southern District of New York",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "Cc: Defense Counsel (By ECF)",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00006174",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Damian Williams",
      "Alison Moe",
      "Lara Pomerantz",
      "Andrew Rohrbach"
    ],
    "organizations": [
      "United States Attorney",
      "Southern District of New York"
    ],
    "locations": [
      "New York"
    ],
    "dates": [
      "11/04/21",
      "2012"
    ],
    "reference_numbers": [
      "Case 1:20-cr-00330-PAE",
      "Document 415",
      "Dkt. No. 407",
      "867 F. Supp. 2d 445",
      "DOJ-OGR-00006174"
    ]
  },
  "additional_notes": "The document appears to be a court filing in a criminal case, with a formal tone and language typical of legal documents. The text is well-formatted and easy to read, with clear headings and signatures. There are no visible redactions or damage to the document."
}