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  "document_metadata": {
    "page_number": "22",
    "document_number": "459",
    "date": "11/15/21",
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  "full_text": "Case 1:20-cr-00330-PAE Document 459 Filed 11/15/21 Page 22 of 43 22\n\n1 any prejudice analysis from other materials on the docket.\n2 And No. 2, I'm still failing to see what the prejudice\n3 is. If you have a grade school math test and you get the\n4 questions in advance, you surely have some sort of advantage.\n5 To the extent we have a juror who has some awareness of the\n6 questionnaires because it's reported in the media in some way,\n7 they will have to truthfully tell us that in the questionnaire\n8 and the voir dire process. We would be able to explore that in\n9 any way, and it's just unclear to me what prejudice you're\n10 seeing as a result of that.\n11 I'll hear you on those two points.\n12 MS. STERNHEIM: Your Honor, I think this is an\n13 extraordinary case, and there has been no ability for the Court\n14 or the government and certainly not the defense to control any\n15 of the vast media coverage in this case, which has\n16 significantly prejudiced our client.\n17 While things are placed on the public record, and\n18 rightly so, this is a situation that is somewhat different.\n19 Giving jurors the opportunity to view the questionnaire before\n20 they come to court to fill it out is like a take-home exam and\n21 they can fill out all the answers and do all the research and\n22 decide what answers they want to put on those papers.\n23 I think that there's an opportunity for people to be\n24 motivated to want to sit on this jury for a variety of reasons,\n25 some of which I have expressed in other filings that have been\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nDOJ-OGR-00006994",
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      "content": "Case 1:20-cr-00330-PAE Document 459 Filed 11/15/21 Page 22 of 43 22",
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      "content": "any prejudice analysis from other materials on the docket. And No. 2, I'm still failing to see what the prejudice is. If you have a grade school math test and you get the questions in advance, you surely have some sort of advantage. To the extent we have a juror who has some awareness of the questionnaires because it's reported in the media in some way, they will have to truthfully tell us that in the questionnaire and the voir dire process. We would be able to explore that in any way, and it's just unclear to me what prejudice you're seeing as a result of that. I'll hear you on those two points.",
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      "content": "MS. STERNHEIM: Your Honor, I think this is an extraordinary case, and there has been no ability for the Court or the government and certainly not the defense to control any of the vast media coverage in this case, which has significantly prejudiced our client. While things are placed on the public record, and rightly so, this is a situation that is somewhat different. Giving jurors the opportunity to view the questionnaire before they come to court to fill it out is like a take-home exam and they can fill out all the answers and do all the research and decide what answers they want to put on those papers. I think that there's an opportunity for people to be motivated to want to sit on this jury for a variety of reasons, some of which I have expressed in other filings that have been",
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      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
      "position": "footer"
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      "content": "DOJ-OGR-00006994",
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  "entities": {
    "people": [
      "MS. STERNHEIM"
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    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
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    "locations": [],
    "dates": [
      "11/15/21"
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    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 459",
      "DOJ-OGR-00006994"
    ]
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}