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    "page_number": "39",
    "document_number": "465",
    "date": "11/15/21",
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  "full_text": "Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 39 of 127\nLB15MAX2\n1 THE COURT: Government 10. Let me say, as a preliminary matter, the government requests that the entirety of this motion be sealed. I have read the government's letter and the footnote 11 in the motion. In my mind they don't justify sealing. As best I can understand the argument the government is saying that the defense should be precluded from make a certain argument because there is no evidence in support of it. If the government is right about that then pretrial publicity would amount to coverage that there is no evidence of that argument. If the government is wrong about that then the evidence in argument comes in so there is no prejudice either way. Frankly, I think the theory of prejudice here runs counter to the whole project of pretrial motion in limine practice which is to litigate, for purposes of trial preparation and trial efficiency and opening statements and the like, what's in and what's out. That's going to sometimes require litigation on what's out. So I don't see a basis to seal this and I think we can discuss it today.\nBut let me begin by simply asking the defense if it intends to make the argument that is outlined in the government's motion 10.\nMS. STERNHEIM: Your Honor, it is too soon to say what we are going to do at trial. Certainly we have no burden of putting on a case and I know the government is well aware of that, but insofar as the government seeks to preclude us from\nSOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300\nDOJ-OGR-00007090",
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      "content": "LB15MAX2",
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      "type": "printed",
      "content": "1 THE COURT: Government 10. Let me say, as a preliminary matter, the government requests that the entirety of this motion be sealed. I have read the government's letter and the footnote 11 in the motion. In my mind they don't justify sealing. As best I can understand the argument the government is saying that the defense should be precluded from make a certain argument because there is no evidence in support of it. If the government is right about that then pretrial publicity would amount to coverage that there is no evidence of that argument. If the government is wrong about that then the evidence in argument comes in so there is no prejudice either way. Frankly, I think the theory of prejudice here runs counter to the whole project of pretrial motion in limine practice which is to litigate, for purposes of trial preparation and trial efficiency and opening statements and the like, what's in and what's out. That's going to sometimes require litigation on what's out. So I don't see a basis to seal this and I think we can discuss it today.\nBut let me begin by simply asking the defense if it intends to make the argument that is outlined in the government's motion 10.",
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    {
      "type": "printed",
      "content": "MS. STERNHEIM: Your Honor, it is too soon to say what we are going to do at trial. Certainly we have no burden of putting on a case and I know the government is well aware of that, but insofar as the government seeks to preclude us from",
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      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
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      "content": "DOJ-OGR-00007090",
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    "people": [
      "THE COURT",
      "MS. STERNHEIM"
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    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C.",
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    "dates": [
      "11/15/21"
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      "Case 1:20-cr-00330-PAE",
      "Document 465",
      "DOJ-OGR-00007090"
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}