{
  "document_metadata": {
    "page_number": "2 of 2",
    "document_number": "34",
    "date": "07/28/20",
    "document_type": "court document",
    "has_handwriting": true,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-0030-AJN Document 34 Filed 07/28/20 Page 2 of 2\nwho has spoken—or who at some future time speaks—by name on the public record in this case, and otherwise be permitted to identify victim names in sealed filings, or identify victims by pseudonyms in public filings, or redact victim names in public filings, but that the defendant and her counsel be restricted from otherwise publicly referencing witness or victim identities. That disagreement is reflected in the differences between the Government's proposed order paragraphs 5, 6, 8, and 16 and the corresponding defense proposed paragraphs 6, 7, 9, and 17.\nb. Second, the defendant and her counsel have proposed certain restrictions on the Government and potential Government witnesses and their counsel. For the reasons set forth in the Government's accompanying letter, the Government does not believe that such restrictions are warranted or appropriate. That disagreement is reflected in the defendant's proposed paragraph 3, which does not have a corresponding paragraph in the Government's proposed order, and in the differences between the Government's proposed order paragraph 4 and the corresponding defense proposed paragraph 5.\n4. I hereby certify that the foregoing statements made by me are true.\nDated: New York, New York July 28, 2020\nAlex Rossmiller\nAssistant United States Attorney\nTelephone: (212) 637-2415\n2\nDOJ-OGR-00001684",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-0030-AJN Document 34 Filed 07/28/20 Page 2 of 2",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "who has spoken—or who at some future time speaks—by name on the public record in this case, and otherwise be permitted to identify victim names in sealed filings, or identify victims by pseudonyms in public filings, or redact victim names in public filings, but that the defendant and her counsel be restricted from otherwise publicly referencing witness or victim identities. That disagreement is reflected in the differences between the Government's proposed order paragraphs 5, 6, 8, and 16 and the corresponding defense proposed paragraphs 6, 7, 9, and 17.\nb. Second, the defendant and her counsel have proposed certain restrictions on the Government and potential Government witnesses and their counsel. For the reasons set forth in the Government's accompanying letter, the Government does not believe that such restrictions are warranted or appropriate. That disagreement is reflected in the defendant's proposed paragraph 3, which does not have a corresponding paragraph in the Government's proposed order, and in the differences between the Government's proposed order paragraph 4 and the corresponding defense proposed paragraph 5.",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "4. I hereby certify that the foregoing statements made by me are true.",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "Dated: New York, New York July 28, 2020",
      "position": "footer"
    },
    {
      "type": "signature",
      "content": "Alex Rossmiller",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "Assistant United States Attorney\nTelephone: (212) 637-2415",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "2",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00001684",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alex Rossmiller"
    ],
    "organizations": [
      "United States Attorney"
    ],
    "locations": [
      "New York"
    ],
    "dates": [
      "July 28, 2020",
      "07/28/20"
    ],
    "reference_numbers": [
      "1:20-cr-0030-AJN",
      "Document 34",
      "DOJ-OGR-00001684"
    ]
  },
  "additional_notes": "The document appears to be a court filing with a signature from Alex Rossmiller, Assistant United States Attorney. The content discusses disagreements between the Government and the defendant regarding proposed order paragraphs and restrictions on publicly referencing witness or victim identities."
}