{
  "document_metadata": {
    "page_number": "2",
    "document_number": "603",
    "date": "02/16/22",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 603 Filed 02/16/22 Page 2 of 3\nPage 2\nfor public access to those questionnaires. Accordingly, it is not necessary to redact discussions of Juror 50's questionnaire from the briefing.\n- The defendant seeks to redact legal arguments about the statistical composition of the jury pool. In particular, the defendant seeks to redact legal arguments about how the Court addressed during jury selection the multiple prospective jurors who disclosed experiencing sexual abuse, assault, or harassment. These redactions are not contemplated by the Court's Order. While quotations or discussions of specific sealed juror materials may be redacted, there is no basis to redact legal arguments about the jury pool as a whole.\n- The defendant seeks to redact \"[d]etails of investigative steps the defense has taken and evidence uncovered thus far.\" (Dkt. No. 602). As an initial matter, the Government notes the defense briefing contains very minimal non-public information. To the extent any of the defendant's proposed redactions address non-public materials, the Court has authorized such redactions.\n- The defendant seeks to redact \"[t]he defense's view of the underlying facts.\" (Dkt. No. 602). But the Court expressly ordered that the parties should not redact legal arguments or discussions of publicly available facts, which is exactly what the defendant now proposes to do. (Dkt. No. 596 at 4). The Court has already ruled that these proposed redactions are not narrowly tailored.\n- The defendant seeks to redact discussions of her \"requested discovery in advance of the hearing.\" (Dkt. No. 602). The Court did not authorize this category of redactions. Moreover, the defendant does not offer any justification for her request, and the Government sees none.\nIn addition, the Government notes that the defendant has proposed redactions to portions\nDOJ-OGR-00008964",
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      "content": "Case 1:20-cr-00330-PAE Document 603 Filed 02/16/22 Page 2 of 3",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Page 2",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "for public access to those questionnaires. Accordingly, it is not necessary to redact discussions of Juror 50's questionnaire from the briefing.\n- The defendant seeks to redact legal arguments about the statistical composition of the jury pool. In particular, the defendant seeks to redact legal arguments about how the Court addressed during jury selection the multiple prospective jurors who disclosed experiencing sexual abuse, assault, or harassment. These redactions are not contemplated by the Court's Order. While quotations or discussions of specific sealed juror materials may be redacted, there is no basis to redact legal arguments about the jury pool as a whole.\n- The defendant seeks to redact \"[d]etails of investigative steps the defense has taken and evidence uncovered thus far.\" (Dkt. No. 602). As an initial matter, the Government notes the defense briefing contains very minimal non-public information. To the extent any of the defendant's proposed redactions address non-public materials, the Court has authorized such redactions.\n- The defendant seeks to redact \"[t]he defense's view of the underlying facts.\" (Dkt. No. 602). But the Court expressly ordered that the parties should not redact legal arguments or discussions of publicly available facts, which is exactly what the defendant now proposes to do. (Dkt. No. 596 at 4). The Court has already ruled that these proposed redactions are not narrowly tailored.\n- The defendant seeks to redact discussions of her \"requested discovery in advance of the hearing.\" (Dkt. No. 602). The Court did not authorize this category of redactions. Moreover, the defendant does not offer any justification for her request, and the Government sees none.\nIn addition, the Government notes that the defendant has proposed redactions to portions",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00008964",
      "position": "footer"
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  ],
  "entities": {
    "people": [],
    "organizations": [
      "Court",
      "Government"
    ],
    "locations": [],
    "dates": [
      "02/16/22"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "603",
      "602",
      "596",
      "DOJ-OGR-00008964"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. The text discusses the defendant's requests to redact certain information from a briefing and the government's response to those requests. The document is well-formatted and free of significant damage or redactions."
}