{
  "document_metadata": {
    "page_number": "18",
    "document_number": "311-1",
    "date": "07/02/21",
    "document_type": "Court Transcript",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 311-1 Filed 07/02/21 Page 18 of 23\nXj3q1gra SEALED\n1 because I don't know anything about the case.\n2 MR. ROSSMILLER: Okay, your Honor, and I think the\n3 answer to that is in a couple parts. The first is, I would\n4 point the Court towards some of the opinions that have talked\n5 about the government's investigative ability and authority\n6 being broad, and it is the case that sometimes we issue grand\n7 jury subpoenas --\n8 THE COURT: But that was true in Martindell too.\n9 MR. ROSSMILLER: Yes, of course, your Honor, but I\n10 just need to say that it is entirely possible that, in any\n11 grand jury subpoena, that materials will come back that are not\n12 helpful to our investigation, are not relevant, for whatever\n13 reason, that it was, however unintentionally, overbroad or\n14 included unnecessary aspects. Here, we are essentially unable\n15 to significantly narrow the request for information in part for\n16 exactly the reasons that you describe. We have either little\n17 or no additional information than the Court does in terms of\n18 what materials there are, who was deposed, and that is in\n19 marked contrast to some of the other cases.\n20 THE COURT: Every other case in the whole world.\n21 MR. ROSSMILLER: Of course, your Honor. Exactly. For\n22 exactly the reasons we described.\n23 So what I can say in terms of assurance is, we are not\n24 sort of an ordinary third-party intervener. All of these\n25 materials will be subject to the extraordinary protections of\nSOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 SDNY_GM_00000869 DOJ-OGR-00004911",
  "text_blocks": [
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      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 311-1 Filed 07/02/21 Page 18 of 23",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Xj3q1gra SEALED",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "1 because I don't know anything about the case.\n2 MR. ROSSMILLER: Okay, your Honor, and I think the\n3 answer to that is in a couple parts. The first is, I would\n4 point the Court towards some of the opinions that have talked\n5 about the government's investigative ability and authority\n6 being broad, and it is the case that sometimes we issue grand\n7 jury subpoenas --\n8 THE COURT: But that was true in Martindell too.\n9 MR. ROSSMILLER: Yes, of course, your Honor, but I\n10 just need to say that it is entirely possible that, in any\n11 grand jury subpoena, that materials will come back that are not\n12 helpful to our investigation, are not relevant, for whatever\n13 reason, that it was, however unintentionally, overbroad or\n14 included unnecessary aspects. Here, we are essentially unable\n15 to significantly narrow the request for information in part for\n16 exactly the reasons that you describe. We have either little\n17 or no additional information than the Court does in terms of\n18 what materials there are, who was deposed, and that is in\n19 marked contrast to some of the other cases.\n20 THE COURT: Every other case in the whole world.\n21 MR. ROSSMILLER: Of course, your Honor. Exactly. For\n22 exactly the reasons we described.\n23 So what I can say in terms of assurance is, we are not\n24 sort of an ordinary third-party intervener. All of these\n25 materials will be subject to the extraordinary protections of",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 SDNY_GM_00000869 DOJ-OGR-00004911",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "MR. ROSSMILLER"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [],
    "dates": [
      "07/02/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "311-1",
      "SDNY_GM_00000869",
      "DOJ-OGR-00004911"
    ]
  },
  "additional_notes": "The document appears to be a court transcript with a header indicating it is sealed. The content is a discussion between MR. ROSSMILLER and THE COURT regarding grand jury subpoenas and investigative authority. The footer includes contact information for SOUTHERN DISTRICT REPORTERS, P.C. and reference numbers."
}