mirror-epstein-docs/results/IMAGES004/DOJ-OGR-00009538.json

{
  "document_metadata": {
    "page_number": "2",
    "document_number": "617",
    "date": "02/24/22",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 617 Filed 02/24/22 Page 2 of 3\nv. Amodeo, 44 F.3d 141, 145 (2d Cir. 1995); see also S.E.C. v. TheStreet.Com, 273 F.3d 222, 232 (2d Cir. 2001) (noting that a \"document which is presented to the court to invoke its powers or affect its decisions\" stands on a \"different footing\" than items merely passed between parties in discovery). The defendant's letter previews her argument on the merits of Juror 50's motion to intervene, which the parties have not yet briefed, yet ignores that the motion is a judicial document whether or not the Court ultimately grants the motion. See Lugosch, 435 F.3d at 121 (rejecting the argument that \"until a district court knows the disposition of the underlying motion, any attempt at calling something a judicial document is premature\").\nThe defendant also argues that Juror 50's motion is not a judicial document because it is a \"discovery request.\" First, Juror 50 is not asking for discovery. He is asking for access to his questionnaire: a document that he himself prepared and swore under penalty of perjury, and which, now that trial is complete, is maintained under seal principally if not entirely to protect his own privacy interests. See, e.g., Press-Enter. Co. v. Superior Ct. of California, Riverside Cty., 464 U.S. 501, 511-12 (1984). Second, the cases the defendant cites address whether discovery materials themselves should be docketed, not whether a motion for discovery should be. The issue here is not whether the questionnaire should be docketed, but whether the motion should be.\nTurning to the balancing factors set forth in Lugosch, the defendant has identified no privacy interest implicated by public filing of the motion, nor could she. Instead, the defendant cites the vague concern that potential witnesses at a hearing may learn Juror 50's views if the motion is unsealed, or that publicity regarding the filing will prejudice her. This argument has no merit. The only substantive factual assertion in the motion is a brief statement that Juror 50 \"does not recall answering questions regarding his prior experience with sexual assault,\" which, as the\n2\nDOJ-OGR-00009538",
  "text_blocks": [
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      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 617 Filed 02/24/22 Page 2 of 3",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "v. Amodeo, 44 F.3d 141, 145 (2d Cir. 1995); see also S.E.C. v. TheStreet.Com, 273 F.3d 222, 232 (2d Cir. 2001) (noting that a \"document which is presented to the court to invoke its powers or affect its decisions\" stands on a \"different footing\" than items merely passed between parties in discovery). The defendant's letter previews her argument on the merits of Juror 50's motion to intervene, which the parties have not yet briefed, yet ignores that the motion is a judicial document whether or not the Court ultimately grants the motion. See Lugosch, 435 F.3d at 121 (rejecting the argument that \"until a district court knows the disposition of the underlying motion, any attempt at calling something a judicial document is premature\").",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "The defendant also argues that Juror 50's motion is not a judicial document because it is a \"discovery request.\" First, Juror 50 is not asking for discovery. He is asking for access to his questionnaire: a document that he himself prepared and swore under penalty of perjury, and which, now that trial is complete, is maintained under seal principally if not entirely to protect his own privacy interests. See, e.g., Press-Enter. Co. v. Superior Ct. of California, Riverside Cty., 464 U.S. 501, 511-12 (1984). Second, the cases the defendant cites address whether discovery materials themselves should be docketed, not whether a motion for discovery should be. The issue here is not whether the questionnaire should be docketed, but whether the motion should be.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Turning to the balancing factors set forth in Lugosch, the defendant has identified no privacy interest implicated by public filing of the motion, nor could she. Instead, the defendant cites the vague concern that potential witnesses at a hearing may learn Juror 50's views if the motion is unsealed, or that publicity regarding the filing will prejudice her. This argument has no merit. The only substantive factual assertion in the motion is a brief statement that Juror 50 \"does not recall answering questions regarding his prior experience with sexual assault,\" which, as the",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "2",
      "position": "footer"
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    {
      "type": "printed",
      "content": "DOJ-OGR-00009538",
      "position": "footer"
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  ],
  "entities": {
    "people": [],
    "organizations": [
      "S.E.C.",
      "TheStreet.Com",
      "Press-Enter. Co.",
      "Superior Ct. of California"
    ],
    "locations": [
      "California",
      "Riverside Cty."
    ],
    "dates": [
      "02/24/22",
      "1984"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 617",
      "44 F.3d 141",
      "273 F.3d 222",
      "435 F.3d at 121",
      "464 U.S. 501"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is well-formatted and easy to read. There are no visible redactions or damage to the document."
}