mirror-epstein-docs/results/IMAGES002/DOJ-OGR-00005561.json

{
  "document_metadata": {
    "page_number": "7",
    "document_number": "383",
    "date": "10/29/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 383 Filed 10/29/21 Page 7 of 40\n\n(E.D.N.Y. Apr. 26, 2011), Dkt. No. 231; United States v. Paris, No. 06 Cr. 64 (CFD), 2007 WL 1484974, at *2 (D. Conn. May 18, 2007).\n\nThe defense largely ignores the overwhelming precedent for the Government's motion, including the recent high profile sex abuse trials in the Eastern District, see United States v. Kelly, No. 19 Cr. 286 (AMD) (E.D.N.Y.); United States v. Raniere, No. 18 Cr. 204 (NGG) (E.D.N.Y. May 6, 2019).1 Instead, the defendant points the Court to the law in civil cases governing motions by plaintiffs seeking to proceed by pseudonyms. (See Def. Opp. at 16 (citing, e.g., Doe v. Cook Cty., Illinois, No. 20 Civ. 5832, 2021 WL 2258313, at *3 (N.D. Ill. June 3, 2021))). This is not a civil case filed by the minor victims, and a civil plaintiff is not similarly situated to a crime victim in a federal criminal case. Civil plaintiffs are generally forced to identify themselves by Rule 10(a) of the Federal Rules of Civil Procedure. See Sealed Plaintiff v. Sealed Defendant, 537 F.3d 185, 188 (2d Cir. 2008). By contrast, crime victims are entitled to the statutory protection of the Crime Victims' Rights Act. See 18 U.S.C. § 3771(a)(8). They have been asked to testify by the Government, and they do not decide whether this case proceeds. There is no reason to look to civil law when a body of criminal cases provides direct guidance on this question.2\n\n1 The defense brief takes pains to distinguish cases the Government cited in its discussion of how courts approach balancing witness and defendant interests in this area, and fails to address nearly all of the cases applying that analysis in the specific context of sex abuse cases like this one. (Compare Def. Opp. at 16-17 & n.19, with Gov't Mot. at 5-7)\n\n2 In discussing the Government's burden to justify privacy safeguards, the defense cites to In re Bonanno, 344 F.2d 830, 833 (2d Cir. 1965), a case about disclosure of the existence of an attorney-client relationship. (Def. Opp. at 15).\n\n6\n\nDOJ-OGR-00005561",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 383 Filed 10/29/21 Page 7 of 40",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "(E.D.N.Y. Apr. 26, 2011), Dkt. No. 231; United States v. Paris, No. 06 Cr. 64 (CFD), 2007 WL 1484974, at *2 (D. Conn. May 18, 2007).\n\nThe defense largely ignores the overwhelming precedent for the Government's motion, including the recent high profile sex abuse trials in the Eastern District, see United States v. Kelly, No. 19 Cr. 286 (AMD) (E.D.N.Y.); United States v. Raniere, No. 18 Cr. 204 (NGG) (E.D.N.Y. May 6, 2019).1 Instead, the defendant points the Court to the law in civil cases governing motions by plaintiffs seeking to proceed by pseudonyms. (See Def. Opp. at 16 (citing, e.g., Doe v. Cook Cty., Illinois, No. 20 Civ. 5832, 2021 WL 2258313, at *3 (N.D. Ill. June 3, 2021))). This is not a civil case filed by the minor victims, and a civil plaintiff is not similarly situated to a crime victim in a federal criminal case. Civil plaintiffs are generally forced to identify themselves by Rule 10(a) of the Federal Rules of Civil Procedure. See Sealed Plaintiff v. Sealed Defendant, 537 F.3d 185, 188 (2d Cir. 2008). By contrast, crime victims are entitled to the statutory protection of the Crime Victims' Rights Act. See 18 U.S.C. § 3771(a)(8). They have been asked to testify by the Government, and they do not decide whether this case proceeds. There is no reason to look to civil law when a body of criminal cases provides direct guidance on this question.2",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "1 The defense brief takes pains to distinguish cases the Government cited in its discussion of how courts approach balancing witness and defendant interests in this area, and fails to address nearly all of the cases applying that analysis in the specific context of sex abuse cases like this one. (Compare Def. Opp. at 16-17 & n.19, with Gov't Mot. at 5-7)\n\n2 In discussing the Government's burden to justify privacy safeguards, the defense cites to In re Bonanno, 344 F.2d 830, 833 (2d Cir. 1965), a case about disclosure of the existence of an attorney-client relationship. (Def. Opp. at 15).",
      "position": "footnote"
    },
    {
      "type": "printed",
      "content": "6",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00005561",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [],
    "organizations": [
      "Government",
      "Court"
    ],
    "locations": [
      "Eastern District",
      "Connecticut",
      "Illinois",
      "New York"
    ],
    "dates": [
      "April 26, 2011",
      "May 18, 2007",
      "May 6, 2019",
      "June 3, 2021",
      "October 29, 2021"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "383",
      "06 Cr. 64 (CFD)",
      "19 Cr. 286 (AMD)",
      "18 Cr. 204 (NGG)",
      "20 Civ. 5832",
      "Dkt. No. 231",
      "2007 WL 1484974",
      "2021 WL 2258313",
      "537 F.3d 185",
      "344 F.2d 830",
      "18 U.S.C. § 3771(a)(8)"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case involving sex abuse allegations. The text is mostly printed, with some footnotes and a header/footer. There are no visible stamps or handwritten text."
}