{
  "document_metadata": {
    "page_number": "2",
    "document_number": "20-2000X08BAJND Document 838-3",
    "date": "12/23/222",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "influenced deliberations. See Dkts. 568-70. When asked about his juror questionnaire, which included a question about whether he had been a victim of sexual abuse, the juror asserted that he \"flew through\" the questionnaire and did \"not recall being asked\" this question. Dkt. 568. Defendant filed a motion for a new trial and asked the Court to keep the motion completely under seal until it ruled on the motion. Dkt. 580. Defendant's request for secrecy is contrary to both the common law and the First Amendment.\n\nThe Common Law Right of Access\n\nThe common law presumption of access attaches to any \"judicial document,\" defined as items \"relevant to the performance of judicial function and useful in the judicial process.\" United States v. Amodeo (\"Amodeo I\"), 44 F.3d 141, 145 (2d Cir. 1995). The presumption is strongest when, as here, documents contribute materially to the Article III powers of the court—that is, to the rendering of verdicts and orders affecting \"substantive legal rights.\" Lugosch v. Pyramid Co. v. Onondaga, 435 F.3d 110, 121 (2d Cir. 2006). Once the right attaches, it is overcome only by a showing that there are \"countervailing factors\" that outweigh the public's right to monitor judicial proceedings.\n\nDefendant's Motion for New Trial. There is no question that Defendant's motion, which will directly inform the Court's assessment of whether a new trial is necessary, is a \"judicial document.\" See Bernstein v. Bernstein Litowitz Berger & Grossman LLP, 814 F.3d 132, 140, 142 (2d Cir. 2016). Because the motion will be used to determine the parties' \"substantive legal rights,\" the presumptive right of access it at its highest. Id.\n\nWe do not see anything on the public record indicating that Defendant has met—or tried to meet—the high showing required to justify a blanket sealing of its motion. It is simply not plausible that every word of a legal filing such as this one requires total secrecy. To the extent that the motion contains any sensitive information, there is a reasonable alternative to wholesale sealing: limited redactions of personally identifiable or sensitive information, if justified under the Lugosch standard. See Amodeo I, 44 F.3d at 147.",
  "text_blocks": [
    {
      "type": "printed",
      "content": "influenced deliberations. See Dkts. 568-70. When asked about his juror questionnaire, which included a question about whether he had been a victim of sexual abuse, the juror asserted that he \"flew through\" the questionnaire and did \"not recall being asked\" this question. Dkt. 568. Defendant filed a motion for a new trial and asked the Court to keep the motion completely under seal until it ruled on the motion. Dkt. 580. Defendant's request for secrecy is contrary to both the common law and the First Amendment.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The Common Law Right of Access",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The common law presumption of access attaches to any \"judicial document,\" defined as items \"relevant to the performance of judicial function and useful in the judicial process.\" United States v. Amodeo (\"Amodeo I\"), 44 F.3d 141, 145 (2d Cir. 1995). The presumption is strongest when, as here, documents contribute materially to the Article III powers of the court—that is, to the rendering of verdicts and orders affecting \"substantive legal rights.\" Lugosch v. Pyramid Co. v. Onondaga, 435 F.3d 110, 121 (2d Cir. 2006). Once the right attaches, it is overcome only by a showing that there are \"countervailing factors\" that outweigh the public's right to monitor judicial proceedings.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Defendant's Motion for New Trial. There is no question that Defendant's motion, which will directly inform the Court's assessment of whether a new trial is necessary, is a \"judicial document.\" See Bernstein v. Bernstein Litowitz Berger & Grossman LLP, 814 F.3d 132, 140, 142 (2d Cir. 2016). Because the motion will be used to determine the parties' \"substantive legal rights,\" the presumptive right of access it at its highest. Id.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "We do not see anything on the public record indicating that Defendant has met—or tried to meet—the high showing required to justify a blanket sealing of its motion. It is simply not plausible that every word of a legal filing such as this one requires total secrecy. To the extent that the motion contains any sensitive information, there is a reasonable alternative to wholesale sealing: limited redactions of personally identifiable or sensitive information, if justified under the Lugosch standard. See Amodeo I, 44 F.3d at 147.",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "2",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00010755",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [],
    "organizations": [
      "United States",
      "Bernstein Litowitz Berger & Grossman LLP"
    ],
    "locations": [],
    "dates": [
      "12/23/222",
      "1995",
      "2006",
      "2016"
    ],
    "reference_numbers": [
      "20-2000X08BAJND Document 838-3",
      "Dkts. 568-70",
      "Dkt. 568",
      "Dkt. 580",
      "44 F.3d 141",
      "435 F.3d 110",
      "814 F.3d 132",
      "DOJ-OGR-00010755"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a legal case, discussing the common law right of access to judicial documents and the defendant's motion for a new trial. The text is well-formatted and printed, with no visible handwriting or stamps."
}