{
  "document_metadata": {
    "page_number": "31",
    "document_number": "382",
    "date": "10/29/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
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  "full_text": "Case 1:20-cr-00330-PAE Document 382 Filed 10/29/21 Page 31 of 69\n\nI. SUPPRESSION OF THE EXHIBITS IS CONTRARY TO WELL-ESTABLISHED SECOND CIRCUIT LAW\n\nAt this point, everyone associated with this litigation knows the definition of a \"judicial document.\" In this Circuit, \"there is a presumption in favor of public inspection and copying of any item entered into evidence at a public session of a trial.\" Application of Nat'l Broad. Co., Inc., 635 F.2d 945, 952 (2d Cir. 1980). Moreover, after \"the evidence has become known to the members of the public, including representatives of the press, through their attendance at a public session of court, it would take the most extraordinary circumstances to justify restrictions on the opportunity of those not physically in attendance at the courtroom to see and hear the evidence, when it is in a form that readily permits sight and sound reproduction.\" Id. Where the requested documents were introduced at trial, the strong weight to be accorded the public right of access to judicial documents was largely derived from the role those documents played in determining litigants' substantive rights -- conduct at the heart of Article III -- and from the need for public monitoring of that conduct. United States v. Graham, 257 F.3d 143, 151 (2d Cir. 2001).\n\nSuppression of any exhibit that contains an accuser's name in this case is doubly problematic -- many of the anticipated exhibits are \"judicial documents\" from other proceedings that have previously been made public or documents already accessible by the public. There is nothing confidential about the exhibits and neither the exhibits nor the names of the witnesses should be redacted or suppressed.\n\nII. PRE-TRIAL RULING ON \"PRIOR CONSISTENT STATEMENTS\" INAPPROPRIATE\n\nThe government seeks a pre-trial ruling that certain unspecified \"prior consistent statements\" of the accusers will be admissible at trial if the defense \"challenges the credibility of the testimony\" of the accusers in some unspecified way. Mot. at 17. Under the government's apparent view, any credibility challenge will permit any prior statement of the government's",
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      "content": "Case 1:20-cr-00330-PAE Document 382 Filed 10/29/21 Page 31 of 69",
      "position": "header"
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    {
      "type": "printed",
      "content": "I. SUPPRESSION OF THE EXHIBITS IS CONTRARY TO WELL-ESTABLISHED SECOND CIRCUIT LAW",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "At this point, everyone associated with this litigation knows the definition of a \"judicial document.\" In this Circuit, \"there is a presumption in favor of public inspection and copying of any item entered into evidence at a public session of a trial.\" Application of Nat'l Broad. Co., Inc., 635 F.2d 945, 952 (2d Cir. 1980). Moreover, after \"the evidence has become known to the members of the public, including representatives of the press, through their attendance at a public session of court, it would take the most extraordinary circumstances to justify restrictions on the opportunity of those not physically in attendance at the courtroom to see and hear the evidence, when it is in a form that readily permits sight and sound reproduction.\" Id. Where the requested documents were introduced at trial, the strong weight to be accorded the public right of access to judicial documents was largely derived from the role those documents played in determining litigants' substantive rights -- conduct at the heart of Article III -- and from the need for public monitoring of that conduct. United States v. Graham, 257 F.3d 143, 151 (2d Cir. 2001).",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Suppression of any exhibit that contains an accuser's name in this case is doubly problematic -- many of the anticipated exhibits are \"judicial documents\" from other proceedings that have previously been made public or documents already accessible by the public. There is nothing confidential about the exhibits and neither the exhibits nor the names of the witnesses should be redacted or suppressed.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "II. PRE-TRIAL RULING ON \"PRIOR CONSISTENT STATEMENTS\" INAPPROPRIATE",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The government seeks a pre-trial ruling that certain unspecified \"prior consistent statements\" of the accusers will be admissible at trial if the defense \"challenges the credibility of the testimony\" of the accusers in some unspecified way. Mot. at 17. Under the government's apparent view, any credibility challenge will permit any prior statement of the government's",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "23",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00005486",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [],
    "organizations": [
      "Nat'l Broad. Co., Inc.",
      "United States"
    ],
    "locations": [],
    "dates": [
      "10/29/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "382",
      "635 F.2d 945",
      "257 F.3d 143",
      "DOJ-OGR-00005486"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is well-formatted and easy to read. There are no visible redactions or damage to the document."
}