{
  "document_metadata": {
    "page_number": "44",
    "document_number": "93",
    "date": "12/10/20",
    "document_type": "court document",
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    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 93 Filed 12/10/20 Page 44 of 91 44\nconfidentiality, as your Honor pointed out. And as you will see in a moment, that explains a lot of the spin the government is putting on facts in this case.\n\nYour Honor, people have received physical threats. My client has received them. Most of those close to her have received them. They have received death threats. They have been injured in their jobs, in their work opportunities, in their reputations, simply for knowing my client. It's real. It's out there. The facts of all the steps the court had to go through just to make the public access available to this proceeding is also a reality.\n\nThere is a real thing out there having a very significant impact on our client. There are folks who would normally come forward as part of a bail package who your Honor is aware of from the Pretrial Services report who can't now, at least at this point, because of the safety and confidentiality concerns. Since last week our firm alone and my colleagues at Haddon Morgan have been besieged with e-mails and posts, some of them threatening. This is all very real. The government attempts to poo-poo it, to give it the back of the hand. It is very real, and we submit it is a factor for the court to consider in its discretion.\n\nBefore I go further, your Honor, I would like to go through the 3142(g) analysis. But before I do that, I would like to make one comment about the CVR -- CVRA proceeding under\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00001921",
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      "content": "Case 1:20-cr-00330-AJN Document 93 Filed 12/10/20 Page 44 of 91 44",
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      "type": "printed",
      "content": "confidentiality, as your Honor pointed out. And as you will see in a moment, that explains a lot of the spin the government is putting on facts in this case.\n\nYour Honor, people have received physical threats. My client has received them. Most of those close to her have received them. They have received death threats. They have been injured in their jobs, in their work opportunities, in their reputations, simply for knowing my client. It's real. It's out there. The facts of all the steps the court had to go through just to make the public access available to this proceeding is also a reality.\n\nThere is a real thing out there having a very significant impact on our client. There are folks who would normally come forward as part of a bail package who your Honor is aware of from the Pretrial Services report who can't now, at least at this point, because of the safety and confidentiality concerns. Since last week our firm alone and my colleagues at Haddon Morgan have been besieged with e-mails and posts, some of them threatening. This is all very real. The government attempts to poo-poo it, to give it the back of the hand. It is very real, and we submit it is a factor for the court to consider in its discretion.\n\nBefore I go further, your Honor, I would like to go through the 3142(g) analysis. But before I do that, I would like to make one comment about the CVR -- CVRA proceeding under",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00001921",
      "position": "footer"
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  ],
  "entities": {
    "people": [],
    "organizations": [
      "Haddon Morgan",
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [],
    "dates": [
      "12/10/20"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "93",
      "DOJ-OGR-00001921"
    ]
  },
  "additional_notes": "The document appears to be a court transcript or legal document. The text is typed, and there are no visible handwritten notes or stamps. The document is from a court case with the reference number 1:20-cr-00330-AJN, document 93, filed on 12/10/20."
}