mirror-epstein-docs/results/IMAGES001/DOJ-OGR-00002800.json

{
  "document_metadata": {
    "page_number": "2",
    "document_number": "172",
    "date": "03/24/21",
    "document_type": "Court Document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "by the proposed subpoena. The Court also gave the alleged victims an opportunity to object to or request modifications of the subpoena as required by Rule 17(c)(3).\n\nOn March 19, 2021, the Court received a letter from the law firm indicating that it can provide notice to alleged victims whose personal or confidential information may be elicited by the subpoena. The law firm shall provide notice to any such alleged victims it represents.\n\nIn that letter, the law firm also interposed substantial objections on behalf of the law firm and the alleged victims it represents. Those objections are functionally the equivalent of a motion to quash, even though the subpoena has not yet issued. So that the Court can receive adversarial briefing on the proposed subpoena comparable to a motion to quash, the law firm shall enter an appearance and file its objections on the public docket. See United States v. Ray, No. 20-CR-110 (LJL), 2020 WL 6939677, at *10 (S.D.N.Y. Nov. 25, 2020) (“[I]f the Court determines that the subpoena calls for personal or confidential information about a victim, it requires the requesting party have given notice to the victim before it permits the service of the subpoena. If the victim objects, the Court will then determine whether to modify or quash the subpoena, including on grounds that Nixon was not satisfied.”).\n\nIn advance of noticing an appearance and filing, the law firm shall meet and confer with defense counsel to see if any issues can be narrowed before formal briefing. Moreover, prior to filing, the law firm shall confer with defense counsel as to any proposed, necessary, and tailored redactions to the objections. The law firm’s objections with any proposed redactions shall be filed on or before March 26, 2021. Any redactions must be justified consistent with Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Within one week of the filing of objections, defense counsel may respond to the subpoena objections. The law firm may reply\n2\nDOJ-OGR-00002800",
  "text_blocks": [
    {
      "type": "printed",
      "content": "by the proposed subpoena. The Court also gave the alleged victims an opportunity to object to or request modifications of the subpoena as required by Rule 17(c)(3).\n\nOn March 19, 2021, the Court received a letter from the law firm indicating that it can provide notice to alleged victims whose personal or confidential information may be elicited by the subpoena. The law firm shall provide notice to any such alleged victims it represents.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "In that letter, the law firm also interposed substantial objections on behalf of the law firm and the alleged victims it represents. Those objections are functionally the equivalent of a motion to quash, even though the subpoena has not yet issued. So that the Court can receive adversarial briefing on the proposed subpoena comparable to a motion to quash, the law firm shall enter an appearance and file its objections on the public docket. See United States v. Ray, No. 20-CR-110 (LJL), 2020 WL 6939677, at *10 (S.D.N.Y. Nov. 25, 2020) (“[I]f the Court determines that the subpoena calls for personal or confidential information about a victim, it requires the requesting party have given notice to the victim before it permits the service of the subpoena. If the victim objects, the Court will then determine whether to modify or quash the subpoena, including on grounds that Nixon was not satisfied.”).",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "In advance of noticing an appearance and filing, the law firm shall meet and confer with defense counsel to see if any issues can be narrowed before formal briefing. Moreover, prior to filing, the law firm shall confer with defense counsel as to any proposed, necessary, and tailored redactions to the objections. The law firm’s objections with any proposed redactions shall be filed on or before March 26, 2021. Any redactions must be justified consistent with Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Within one week of the filing of objections, defense counsel may respond to the subpoena objections. The law firm may reply",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "2",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00002800",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [],
    "organizations": [
      "Court",
      "law firm",
      "defense counsel"
    ],
    "locations": [
      "S.D.N.Y.",
      "Onondaga"
    ],
    "dates": [
      "March 19, 2021",
      "Nov. 25, 2020",
      "March 26, 2021"
    ],
    "reference_numbers": [
      "Case 1:20-cr-00330-PAE",
      "Document 172",
      "No. 20-CR-110 (LJL)",
      "435 F.3d 110",
      "DOJ-OGR-00002800"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is printed and there are no visible stamps or handwritten notes. The document is page 2 of 3."
}