{
  "document_metadata": {
    "page_number": "7",
    "document_number": "590",
    "date": "02/01/22",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 590 Filed 02/01/22 Page 7 of 9\n\nThe Honorable Alison J. Nathan\nFebruary 1, 2022\nPage 7\n\n2008, No. 08-M-208 (DRH), 2008 WL 5667021, at *4 (N.D.N.Y. Jul. 14, 2008) (declining to unseal search warrant applications and affidavits because \"[i]f such information is disclosed to the subjects of investigations before the institution of charges, there exists a risk that those individuals could conceal or destroy other evidence, influence information and testimony given by others, and otherwise delay and obstruct the investigation.\")\n\nJudge Caproni's decision in United States v. Silver offers a useful example. In Silver, the government filed under seal a pretrial motion in limine, which described the defendant's extra-marital affairs and sought permission to admit this evidence if the defendant put at issue his ethics or integrity or his character for truthfulness and honesty, among other things. Silver, 2016 WL 15732993, at *1. Judge Caproni heard argument on the motion in a closed proceeding two weeks before trial and ruled that the submissions on this issue would remain under seal until the conclusion of the trial due to the concern that public disclosure of the defendant's extramarital affairs so close to trial would \"increase the difficulty of picking a jury\" and thereby impact the defendant's right to a fair trial. Id. at *2, *8. Following the defendant's conviction, Judge Caproni gave the parties the opportunity to brief whether the submissions should remain sealed. Id. at *2. She ultimately ruled that the fair trial concerns that led her to temporarily seal the submissions no longer existed and ordered them to be unsealed. Id. at *8.\n\nThe Court should follow the example of Judge Caproni in Silver. Here, to protect Ms. Maxwell's right to a fair trial, it is necessary to temporarily seal the Motion (and likely any additional submissions on this issue) for a short period of time until the Court rules on the Motion or until any additional fact-finding process ordered by the Court is complete. The Motion and\n\n2087306.1\n\nDOJ-OGR-00008858",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 590 Filed 02/01/22 Page 7 of 9",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "The Honorable Alison J. Nathan\nFebruary 1, 2022\nPage 7",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "2008, No. 08-M-208 (DRH), 2008 WL 5667021, at *4 (N.D.N.Y. Jul. 14, 2008) (declining to unseal search warrant applications and affidavits because \"[i]f such information is disclosed to the subjects of investigations before the institution of charges, there exists a risk that those individuals could conceal or destroy other evidence, influence information and testimony given by others, and otherwise delay and obstruct the investigation.\")",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Judge Caproni's decision in United States v. Silver offers a useful example. In Silver, the government filed under seal a pretrial motion in limine, which described the defendant's extra-marital affairs and sought permission to admit this evidence if the defendant put at issue his ethics or integrity or his character for truthfulness and honesty, among other things. Silver, 2016 WL 15732993, at *1. Judge Caproni heard argument on the motion in a closed proceeding two weeks before trial and ruled that the submissions on this issue would remain under seal until the conclusion of the trial due to the concern that public disclosure of the defendant's extramarital affairs so close to trial would \"increase the difficulty of picking a jury\" and thereby impact the defendant's right to a fair trial. Id. at *2, *8. Following the defendant's conviction, Judge Caproni gave the parties the opportunity to brief whether the submissions should remain sealed. Id. at *2. She ultimately ruled that the fair trial concerns that led her to temporarily seal the submissions no longer existed and ordered them to be unsealed. Id. at *8.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The Court should follow the example of Judge Caproni in Silver. Here, to protect Ms. Maxwell's right to a fair trial, it is necessary to temporarily seal the Motion (and likely any additional submissions on this issue) for a short period of time until the Court rules on the Motion or until any additional fact-finding process ordered by the Court is complete. The Motion and",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "2087306.1",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00008858",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Judge Caproni",
      "Ms. Maxwell"
    ],
    "organizations": [
      "Court",
      "DOJ"
    ],
    "locations": [
      "N.D.N.Y."
    ],
    "dates": [
      "February 1, 2022",
      "Jul. 14, 2008"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 590",
      "No. 08-M-208 (DRH)",
      "2008 WL 5667021",
      "2016 WL 15732993",
      "2087306.1",
      "DOJ-OGR-00008858"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case United States v. Maxwell. The text is printed and there are no visible stamps or handwritten notes. The document is page 7 of 9."
}