{
  "document_metadata": {
    "page_number": "7",
    "document_number": "33",
    "date": "July 28, 2020",
    "document_type": "Court Document",
    "has_handwriting": true,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 33 Filed 07/28/20 Page 7 of 7\nThe Honorable Alison J. Nathan\nJuly 28, 2020\nPage 7\nof such materials provided by the defendant to the Government. But there is no basis to add additional restrictions upon the Government's use of materials gathered by the Government itself.\nThe defendant's only counter-argument, as noted—that this Court should put third parties \"on equal footing with the defense\"—is both unlikely to be relevant given the Government's standard practice, as described above, and, the Government submits, an irrelevant consideration in the context of a criminal protective order. Indeed, the Government respectfully submits that neither it nor this Court is well-positioned to, or should, become the arbiter of what is appropriate or permissible in civil cases.\nIn sum, the defendant's attempt to restrict the Government and to restrict third parties in this way appears to be unprecedented, and is without legal basis, and should be denied.\nAccordingly, for the reasons set forth above, the Court should enter the Government's proposed protective order, which is enclosed, and deny the defendant's motion.\nRespectfully submitted,\nAUDREY STRAUSS\nActing United States Attorney\nBy: _______________________\nAlex Rossmiller / Alison Moe / Maurene Comey\nAssistant United States Attorneys\nSouthern District of New York\nTel: (212) 637-2415\nCc: All counsel of record (via ECF)\nDOJ-OGR-00001670",
  "text_blocks": [
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      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 33 Filed 07/28/20 Page 7 of 7",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "The Honorable Alison J. Nathan\nJuly 28, 2020\nPage 7",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "of such materials provided by the defendant to the Government. But there is no basis to add additional restrictions upon the Government's use of materials gathered by the Government itself.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "The defendant's only counter-argument, as noted—that this Court should put third parties \"on equal footing with the defense\"—is both unlikely to be relevant given the Government's standard practice, as described above, and, the Government submits, an irrelevant consideration in the context of a criminal protective order. Indeed, the Government respectfully submits that neither it nor this Court is well-positioned to, or should, become the arbiter of what is appropriate or permissible in civil cases.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "In sum, the defendant's attempt to restrict the Government and to restrict third parties in this way appears to be unprecedented, and is without legal basis, and should be denied.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Accordingly, for the reasons set forth above, the Court should enter the Government's proposed protective order, which is enclosed, and deny the defendant's motion.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Respectfully submitted,",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "AUDREY STRAUSS\nActing United States Attorney",
      "position": "body"
    },
    {
      "type": "handwritten",
      "content": "_______________________",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Alex Rossmiller / Alison Moe / Maurene Comey\nAssistant United States Attorneys\nSouthern District of New York\nTel: (212) 637-2415",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Cc: All counsel of record (via ECF)",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00001670",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Audrey Strauss",
      "Alex Rossmiller",
      "Alison Moe",
      "Maurene Comey"
    ],
    "organizations": [
      "United States Attorney",
      "Southern District of New York"
    ],
    "locations": [
      "New York"
    ],
    "dates": [
      "July 28, 2020"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "Document 33",
      "DOJ-OGR-00001670",
      "(212) 637-2415"
    ]
  },
  "additional_notes": "The document appears to be a court filing with a signature line that has been signed with a placeholder line, indicating that the actual signature is not present on this digital version. The document is well-formatted and legible."
}