{
  "document_metadata": {
    "page_number": "21",
    "document_number": "311-1",
    "date": "07/02/21",
    "document_type": "court transcript",
    "has_handwriting": false,
    "has_stamps": false
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  "full_text": "Case 1:20-cr-00330-PAE Document 311-1 Filed 07/02/21 Page 21 of 23\n\nxj3q1gra\n\nSEALED\n\n1 procedure of either having the target of the subpoena make a\n2 motion to quash or a motion for relief or the government moving\n3 for relief to intervene, instead of engaging in self-help.\n4 There isn't an application like this in any case except the\n5 Chemical Bank case, and in the Chemical Bank case, it all was\n6 ex post facto and it all happened.\n7 MR. ROSSMILLER: Right. And I'll just note, without\n8 wanting to be defensive at all about the posture -- I\n9 understand the Court's questions about that -- I cannot recall\n10 whether it was Martindell or one of the other cases, but one of\n11 the original cases in this line, one of the issues was that the\n12 court had gotten on the phone with the judge and requested it,\n13 you know, sort of informally, right?\n14 THE COURT: Yes.\n15 MR. ROSSMILLER: Despite our errors in the precise\n16 procedure, we did want to have a formal application with\n17 reasons and then subsequently, at the request of Judge Sweet,\n18 supporting law. And so I do apologize for the precise posture.\n19 We took the approach that we did in the hopes that we could\n20 avoid the types of problems that had been engendered by other\n21 types of applications which I think were made by the government\n22 in other cases, and so that's what we did here as well.\n23 THE COURT: Okay. All right. Well, I'll tell you one\n24 thing that I am going to do. I am going to ask the clerk of\n25 the court to assign a miscellaneous number to this case and\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300 SDNY_GM_00000872 DOJ-OGR-00004914",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 311-1 Filed 07/02/21 Page 21 of 23",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "xj3q1gra\n\nSEALED",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "1 procedure of either having the target of the subpoena make a\n2 motion to quash or a motion for relief or the government moving\n3 for relief to intervene, instead of engaging in self-help.\n4 There isn't an application like this in any case except the\n5 Chemical Bank case, and in the Chemical Bank case, it all was\n6 ex post facto and it all happened.\n7 MR. ROSSMILLER: Right. And I'll just note, without\n8 wanting to be defensive at all about the posture -- I\n9 understand the Court's questions about that -- I cannot recall\n10 whether it was Martindell or one of the other cases, but one of\n11 the original cases in this line, one of the issues was that the\n12 court had gotten on the phone with the judge and requested it,\n13 you know, sort of informally, right?\n14 THE COURT: Yes.\n15 MR. ROSSMILLER: Despite our errors in the precise\n16 procedure, we did want to have a formal application with\n17 reasons and then subsequently, at the request of Judge Sweet,\n18 supporting law. And so I do apologize for the precise posture.\n19 We took the approach that we did in the hopes that we could\n20 avoid the types of problems that had been engendered by other\n21 types of applications which I think were made by the government\n22 in other cases, and so that's what we did here as well.\n23 THE COURT: Okay. All right. Well, I'll tell you one\n24 thing that I am going to do. I am going to ask the clerk of\n25 the court to assign a miscellaneous number to this case and",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300 SDNY_GM_00000872 DOJ-OGR-00004914",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "MR. ROSSMILLER",
      "Judge Sweet"
    ],
    "organizations": [
      "Chemical Bank",
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [],
    "dates": [
      "07/02/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "311-1",
      "SDNY_GM_00000872",
      "DOJ-OGR-00004914"
    ]
  },
  "additional_notes": "The document appears to be a court transcript with a header indicating it is sealed. The content discusses legal procedures and references to other cases. The footer contains information about the court reporters and reference numbers."
}