{
  "document_metadata": {
    "page_number": "9",
    "document_number": "140",
    "date": "02/04/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 140 Filed 02/04/21 Page 9 of 22 See Motion under the Due Process Clause to Suppress and Dismiss Counts 5 and 6, Ex. D, at 17 (emphasis added). The government's representations to were, of course, false. The government met with file and who was before it issued the subpoena, it knew what was in , and it nevertheless disclaimed any ability to narrowly tailor any subpoena. Given \"its knowledge about the matter under investigation,\" the government's failure to make any effort, much less a \"reasonable effort,\" to request \"only those documents that are relevant and non-privileged,\" renders the subpoena overbroad and unconstitutional. See In re Grand Jury Subpoena, JK-15-029, 828 F.3d at 1088. So overbroad was the subpoena that actually produced to the government It is obvious why the Fourth Amendment requires suppression Id. at 1089. This type of overbroad subpoena is exactly what the Fourth Amendment is designed to prohibit: searches that invade \"the privacies of life\" from \"arbitrary\" power and \"police surveillance\" that is \"too permeating.\" See Carpenter, 138 S. Ct. at 2213 (quoting Smith v. Maryland, 442 U.S. 735, 740 (1979)). Otherwise, \"when the government seeks all material of a broad generic type that a party possesses—every piece of paper in a corporation's files, for example, or, as in this case,\" every piece of paper in a file, \"a reasonable possibility that some of that material would be relevant would suffice to validate the subpoena, no matter how vast its sweep, and no matter the 5 DOJ-OGR-00002557",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 140 Filed 02/04/21 Page 9 of 22",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "See Motion under the Due Process Clause to Suppress and Dismiss Counts 5 and 6, Ex. D, at 17 (emphasis added). The government's representations to were, of course, false. The government met with file and who was before it issued the subpoena, it knew what was in , and it nevertheless disclaimed any ability to narrowly tailor any subpoena. Given \"its knowledge about the matter under investigation,\" the government's failure to make any effort, much less a \"reasonable effort,\" to request \"only those documents that are relevant and non-privileged,\" renders the subpoena overbroad and unconstitutional. See In re Grand Jury Subpoena, JK-15-029, 828 F.3d at 1088. So overbroad was the subpoena that actually produced to the government It is obvious why the Fourth Amendment requires suppression Id. at 1089. This type of overbroad subpoena is exactly what the Fourth Amendment is designed to prohibit: searches that invade \"the privacies of life\" from \"arbitrary\" power and \"police surveillance\" that is \"too permeating.\" See Carpenter, 138 S. Ct. at 2213 (quoting Smith v. Maryland, 442 U.S. 735, 740 (1979)). Otherwise, \"when the government seeks all material of a broad generic type that a party possesses—every piece of paper in a corporation's files, for example, or, as in this case,\" every piece of paper in a file, \"a reasonable possibility that some of that material would be relevant would suffice to validate the subpoena, no matter how vast its sweep, and no matter the",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "5",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00002557",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [],
    "organizations": [],
    "locations": [],
    "dates": [
      "02/04/21",
      "1979"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "Document 140",
      "JK-15-029",
      "DOJ-OGR-00002557"
    ]
  },
  "additional_notes": "The document appears to be a court filing with redactions. The redactions are likely due to sensitive information being removed."
}