{
  "document_metadata": {
    "page_number": "20",
    "document_number": "383",
    "date": "10/29/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 383 Filed 10/29/21 Page 20 of 40\n\nFinally, the defense argues that this motion is purely tactical on the part of the Government, because this motion affords sympathy to the victims. (Def. Opp. at 22). Remarkably—and unfortunately—the defense again repeats their claim that testimony is being fabricated. (Id.). The Government is responding to the real concerns of its victims, as it is duty-bound to do, and as is common in cases involving sexual abuse. It has also already agreed to a jury instruction, as is sometimes given in these cases, explaining that the use of pseudonyms and first names should not be held against the defendant. (See Gov't Mot. at 14 n.4). If any tactical gamesmanship is occurring, it is on the part of the defense, which spends a few paragraphs out of nearly twenty pages of their brief offering conclusory reasons why privacy safeguards undermine a defense interest. As the defense is well aware, such safeguards are significant to the Minor Victims and their willingness to testify. But the Court need not arbitrate issues of litigation tactics. The balance of interests on this issue is clear and weighs in favor of privacy safeguards, as it did in many other trials involving sex crimes.\n\nE. Sealing Related Exhibits is Entirely Appropriate\n\nJust as the Government's proposal is narrowly tailored with respect to the defendant, so it is narrowly tailored with respect to the right of the public and the press to access the trial. The public and press are free to attend the entire trial. They may observe each of the Minor Victims, in person, testify in full. At no point during testimony is the Government seeking closure of the courtroom. The public and the press are also welcome to see most of the trial exhibits.\n\nThe only narrow exception is for those exhibits that specifically contain identifying information of Minor Victims. As the Court is well aware, the right to access trial evidence is not absolute, and it can be overcome—especially by information that is “traditionally considered 19\n\nDOJ-OGR-00005574",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 383 Filed 10/29/21 Page 20 of 40",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Finally, the defense argues that this motion is purely tactical on the part of the Government, because this motion affords sympathy to the victims. (Def. Opp. at 22). Remarkably—and unfortunately—the defense again repeats their claim that testimony is being fabricated. (Id.). The Government is responding to the real concerns of its victims, as it is duty-bound to do, and as is common in cases involving sexual abuse. It has also already agreed to a jury instruction, as is sometimes given in these cases, explaining that the use of pseudonyms and first names should not be held against the defendant. (See Gov't Mot. at 14 n.4). If any tactical gamesmanship is occurring, it is on the part of the defense, which spends a few paragraphs out of nearly twenty pages of their brief offering conclusory reasons why privacy safeguards undermine a defense interest. As the defense is well aware, such safeguards are significant to the Minor Victims and their willingness to testify. But the Court need not arbitrate issues of litigation tactics. The balance of interests on this issue is clear and weighs in favor of privacy safeguards, as it did in many other trials involving sex crimes.",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "E. Sealing Related Exhibits is Entirely Appropriate",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "Just as the Government's proposal is narrowly tailored with respect to the defendant, so it is narrowly tailored with respect to the right of the public and the press to access the trial. The public and press are free to attend the entire trial. They may observe each of the Minor Victims, in person, testify in full. At no point during testimony is the Government seeking closure of the courtroom. The public and the press are also welcome to see most of the trial exhibits.",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "The only narrow exception is for those exhibits that specifically contain identifying information of Minor Victims. As the Court is well aware, the right to access trial evidence is not absolute, and it can be overcome—especially by information that is “traditionally considered 19",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00005574",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Minor Victims"
    ],
    "organizations": [
      "Government"
    ],
    "locations": [],
    "dates": [
      "10/29/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 383",
      "DOJ-OGR-00005574"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case involving sexual abuse. The text discusses the government's motion to protect the privacy of minor victims and the defense's objections to the motion. The document is well-formatted and free of significant damage or redactions."
}