mirror-epstein-docs/results/IMAGES004/DOJ-OGR-00009844.json

{
  "document_metadata": {
    "page_number": "46 of 49",
    "document_number": "643",
    "date": "03/11/22",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 643 Filed 03/11/22 Page 46 of 49\n\nMoreover, there can be no real concern, as the defendant claims, that providing Juror 50 with his questionnaire will \"color\" Juror 50's testimony and interfere with the integrity of a hearing. (Def. Mem. at 53). Should the Court decide to conduct a limited hearing, as the Government has proposed, the Court will undoubtedly ask Juror 50 about his questionnaire. Juror 50 should have access to his own questionnaire in advance of any such hearing so that he can speak with his counsel and assess whether he plans to invoke his rights under the Fifth Amendment.\n\nMore broadly speaking, \"[t]he object of the proceeding is to permit the truth to be discovered with the least possible harm to other interests.\" Gagnon, 282 F. App'x at 40. That endeavor is not furthered by surprising Juror 50 on the stand with a document he does not seem to recall with specificity. See Juror 50 Mem. at 4 (stating that Juror 50 \"does not recall answering questions [in the questionnaire] regarding his prior experience with sexual assault\"). To deny Juror 50 access to his own document means, practically speaking, that after being shown the questionnaire and asked questions about the document at a hearing, Juror 50 will need to speak with his counsel, assuredly delaying the hearing.\n\nTo the extent Juror 50's motion seeks leave to submit briefing on the merits of this inquiry, the Government agrees with the defendant that Juror 50 need not be permitted to intervene or be heard on the scope of the Court's inquiry, at least not at this juncture. The parties are well situated to brief the appropriate scope of any hearing without intervention from the witness at that hearing. However, if the Court does authorize the subpoenas compelling production of Juror 50's communications and other information—though it should not, for the reasons set forth above—Juror 50 should have an opportunity to move to quash those subpoenas. See, e.g., City of Almaty, Kazakhstan v. Ablyazov, No. 1:15 Civ. 05345 (AJN) (KHP), 2020 WL 1130670, at *1 (S.D.N.Y.\n\n44\n\nDOJ-OGR-00009844",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 643 Filed 03/11/22 Page 46 of 49",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Moreover, there can be no real concern, as the defendant claims, that providing Juror 50 with his questionnaire will \"color\" Juror 50's testimony and interfere with the integrity of a hearing. (Def. Mem. at 53). Should the Court decide to conduct a limited hearing, as the Government has proposed, the Court will undoubtedly ask Juror 50 about his questionnaire. Juror 50 should have access to his own questionnaire in advance of any such hearing so that he can speak with his counsel and assess whether he plans to invoke his rights under the Fifth Amendment.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "More broadly speaking, \"[t]he object of the proceeding is to permit the truth to be discovered with the least possible harm to other interests.\" Gagnon, 282 F. App'x at 40. That endeavor is not furthered by surprising Juror 50 on the stand with a document he does not seem to recall with specificity. See Juror 50 Mem. at 4 (stating that Juror 50 \"does not recall answering questions [in the questionnaire] regarding his prior experience with sexual assault\"). To deny Juror 50 access to his own document means, practically speaking, that after being shown the questionnaire and asked questions about the document at a hearing, Juror 50 will need to speak with his counsel, assuredly delaying the hearing.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "To the extent Juror 50's motion seeks leave to submit briefing on the merits of this inquiry, the Government agrees with the defendant that Juror 50 need not be permitted to intervene or be heard on the scope of the Court's inquiry, at least not at this juncture. The parties are well situated to brief the appropriate scope of any hearing without intervention from the witness at that hearing. However, if the Court does authorize the subpoenas compelling production of Juror 50's communications and other information—though it should not, for the reasons set forth above—Juror 50 should have an opportunity to move to quash those subpoenas. See, e.g., City of Almaty, Kazakhstan v. Ablyazov, No. 1:15 Civ. 05345 (AJN) (KHP), 2020 WL 1130670, at *1 (S.D.N.Y.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "44",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00009844",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Juror 50",
      "Ablyazov"
    ],
    "organizations": [
      "Government",
      "Court"
    ],
    "locations": [
      "S.D.N.Y.",
      "Kazakhstan",
      "Almaty"
    ],
    "dates": [
      "03/11/22"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 643",
      "1:15 Civ. 05345 (AJN) (KHP)"
    ]
  },
  "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 46 of 49."
}