{ "document_metadata": { "page_number": "2", "document_number": "789", "date": "07/22/25", "document_type": "court document", "has_handwriting": false, "has_stamps": false }, "full_text": "Case 1:20-cr-00330-PAE Document 789 Filed 07/22/25 Page 2 of 4\n\nare certain \"special circumstances\" in which release of grand jury records is appropriate, based upon a court's supervisory authority over grand juries it empanels. See In re Craig, 131 F.3d at 102; see also id. at 104 (\"The discretion of a trial court in deciding whether to make public the ordinarily secret proceedings of a grand jury investigation is one of the broadest and most sensitive exercises of careful judgment that a trial judge can make.\"). The Second Circuit has identified the following as a non-exhaustive list of factors for district courts to weigh in considering applications for disclosure:\n\n- the identity of the party seeking disclosure;\n- whether the defendant to the grand jury proceeding or the Government opposes the disclosure;\n- why disclosure is being sought in the particular case;\n- what specific information is being sought for disclosure;\n- how long ago the grand jury proceedings took place;\n- the current status of the principals of the grand jury proceedings and that of their families;\n- the extent to which the desired material - either permissibly or impermissibly - has been previously made public;\n- whether witnesses to the grand jury proceedings who might be affected by disclosure are still alive; and\n- [whether there is an] additional need for maintaining secrecy in the particular case in question.\n\nId. at 106 (capitalization altered); see also Laws. 'Comm. for 9/11 Inquiry, Inc. v. Garland, 43 F.4th 276, 285 (2d Cir. 2022) (affirming district court's application of those factors).2\n\n2 The Seventh Circuit is in accord that a district court may order the release of grand jury materials upon a showing of special circumstances. See Carlson v. United States, 837 F.3d 753, 766-67 (7th Cir. 2016). Other circuits have taken a narrower view of a court's authority to order such relief. See, e.g., McKeever v Barr, 920 F.3d 842, 843, 850 (D.C. Cir. 2019), cert denied,", "text_blocks": [ { "type": "printed", "content": "Case 1:20-cr-00330-PAE Document 789 Filed 07/22/25 Page 2 of 4", "position": "header" }, { "type": "printed", "content": "are certain \"special circumstances\" in which release of grand jury records is appropriate, based upon a court's supervisory authority over grand juries it empanels. See In re Craig, 131 F.3d at 102; see also id. at 104 (\"The discretion of a trial court in deciding whether to make public the ordinarily secret proceedings of a grand jury investigation is one of the broadest and most sensitive exercises of careful judgment that a trial judge can make.\"). The Second Circuit has identified the following as a non-exhaustive list of factors for district courts to weigh in considering applications for disclosure:", "position": "body" }, { "type": "printed", "content": "- the identity of the party seeking disclosure;\n- whether the defendant to the grand jury proceeding or the Government opposes the disclosure;\n- why disclosure is being sought in the particular case;\n- what specific information is being sought for disclosure;\n- how long ago the grand jury proceedings took place;\n- the current status of the principals of the grand jury proceedings and that of their families;\n- the extent to which the desired material - either permissibly or impermissibly - has been previously made public;\n- whether witnesses to the grand jury proceedings who might be affected by disclosure are still alive; and\n- [whether there is an] additional need for maintaining secrecy in the particular case in question.", "position": "body" }, { "type": "printed", "content": "Id. at 106 (capitalization altered); see also Laws. 'Comm. for 9/11 Inquiry, Inc. v. Garland, 43 F.4th 276, 285 (2d Cir. 2022) (affirming district court's application of those factors).2", "position": "body" }, { "type": "printed", "content": "2 The Seventh Circuit is in accord that a district court may order the release of grand jury materials upon a showing of special circumstances. See Carlson v. United States, 837 F.3d 753, 766-67 (7th Cir. 2016). Other circuits have taken a narrower view of a court's authority to order such relief. See, e.g., McKeever v Barr, 920 F.3d 842, 843, 850 (D.C. Cir. 2019), cert denied,", "position": "body" }, { "type": "printed", "content": "DOJ-OGR-00015048", "position": "footer" } ], "entities": { "people": [], "organizations": [ "Second Circuit", "Seventh Circuit", "D.C. Cir." ], "locations": [], "dates": [ "07/22/25", "2016", "2019", "2022" ], "reference_numbers": [ "1:20-cr-00330-PAE", "789", "131 F.3d", "837 F.3d 753", "920 F.3d 842", "43 F.4th 276" ] }, "additional_notes": "The document appears to be a court filing related to a grand jury investigation. The text is printed and there are no visible stamps or handwritten notes. The document is page 2 of 4." }