{
  "document_metadata": {
    "page_number": "3",
    "document_number": "2020-0088",
    "date": "February 1, 2022",
    "document_type": "Court Document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "The Honorable Alison J. Nathan\nFebruary 1, 2022\nPage 3\n\npublicity that will undoubtedly surround the unsealing of the Motion will influence the memories\nof other potential witnesses. All of this will frustrate the truth-seeking process of any factual\ninquiry ordered by the Court and jeopardize Ms. Maxwell's one chance to vindicate her right to a\nfair trial.\n\nFor the reasons set forth more fully below, Ms. Maxwell's right to a fair trial is a \"higher\nvalue\" and a compelling interest that outweighs the public's qualified right of access to the Motion\nunder both the common law and the First Amendment. The Court should therefore order that the\nMotion remain temporarily sealed until the Court rules on Ms. Maxwell's Motion or until the\nconclusion of any hearing ordered by the Court, whichever comes first.1\n\nApplicable Law\n\nIt is well settled that the public and the press have a qualified right of access to judicial\ndocuments filed in criminal and civil proceedings under both the First Amendment and the\ncommon law. See Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 119-20 (2d Cir. 2006);\nUnited States v. Silver, No. 15-CR-93 (VEC), 2016 WL 1572993, at *3 (S.D.N.Y. Apr. 14, 2016).\n\"The presumption of access is based on the need for federal courts, although independent—\nindeed, particularly because they are independent—to have a measure of accountability and for the\npublic to have confidence in the administration of justice.\" United States v. Amodeo, 71 F.3d\n1044, 1048 (2d Cir. 1995) (\"Amodeo II\").\n\n1 The defense anticipates that the government's response will raise the same issues and will need to be sealed for the\nsame reasons. Accordingly, the defense further requests that that Court order the government to file its response\ntemporarily under seal to give the defense the opportunity to assert its position regarding sealing.\n\n2087306.1\nDOJ-OGR-00008902",
  "text_blocks": [
    {
      "type": "printed",
      "content": "The Honorable Alison J. Nathan\nFebruary 1, 2022\nPage 3",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "publicity that will undoubtedly surround the unsealing of the Motion will influence the memories\nof other potential witnesses. All of this will frustrate the truth-seeking process of any factual\ninquiry ordered by the Court and jeopardize Ms. Maxwell's one chance to vindicate her right to a\nfair trial.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "For the reasons set forth more fully below, Ms. Maxwell's right to a fair trial is a \"higher\nvalue\" and a compelling interest that outweighs the public's qualified right of access to the Motion\nunder both the common law and the First Amendment. The Court should therefore order that the\nMotion remain temporarily sealed until the Court rules on Ms. Maxwell's Motion or until the\nconclusion of any hearing ordered by the Court, whichever comes first.1",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Applicable Law",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "It is well settled that the public and the press have a qualified right of access to judicial\ndocuments filed in criminal and civil proceedings under both the First Amendment and the\ncommon law. See Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 119-20 (2d Cir. 2006);\nUnited States v. Silver, No. 15-CR-93 (VEC), 2016 WL 1572993, at *3 (S.D.N.Y. Apr. 14, 2016).\n\"The presumption of access is based on the need for federal courts, although independent—\nindeed, particularly because they are independent—to have a measure of accountability and for the\npublic to have confidence in the administration of justice.\" United States v. Amodeo, 71 F.3d\n1044, 1048 (2d Cir. 1995) (\"Amodeo II\").",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "1 The defense anticipates that the government's response will raise the same issues and will need to be sealed for the\nsame reasons. Accordingly, the defense further requests that that Court order the government to file its response\ntemporarily under seal to give the defense the opportunity to assert its position regarding sealing.",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "2087306.1\nDOJ-OGR-00008902",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ms. Maxwell"
    ],
    "organizations": [
      "Court",
      "Government"
    ],
    "locations": [
      "Onondaga",
      "S.D.N.Y."
    ],
    "dates": [
      "February 1, 2022",
      "Apr. 14, 2016"
    ],
    "reference_numbers": [
      "2020-0088",
      "15-CR-93 (VEC)",
      "2087306.1",
      "DOJ-OGR-00008902"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Ms. Maxwell. The text is mostly printed, with no visible handwriting or stamps. The document is page 3 of a larger filing."
}