mirror-epstein-docs/results/IMAGES004/DOJ-OGR-00010754.json

{
  "document_metadata": {
    "page_number": "11",
    "document_number": "20-cr-00330",
    "date": "January 24, 2022",
    "document_type": "Letter",
    "has_handwriting": true,
    "has_stamps": true
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 583 Filed 10/25/22 Page 11 of 5353\n\nThe New York Times Company\nDavid McCraw\nSenior Vice President &\nDeputy General Counsel\nT 212 556 4031\nmccraw@nytimes.com\n620 8th Avenue\nNew York, NY 10018\nnytimes.com\nJanuary 24, 2022\n\nVIA EMAIL AND FEDEX\n\nThe Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\nUnited States Courthouse\n40 Foley Square\nNew York, NY 10007\n\nRe: United States v. Maxwell, No. 20-cr-00330 (AJN) - Unsealing of Defendant's Motion for a New Trial and Questionnaires of Seated Jurors\n\nDear Judge Nathan:\n\nI write on behalf of The New York Times Company (\"The Times\") to request that the Court unseal (a) Defendant's Motion for a New Trial and accompanying brief and exhibits (Dkt. 580) and (b) the filled-out questionnaires for the twelve seated jurors. These records are subject to both First Amendment and common law rights of access, which set stringent standards for sealing.1 We ask that the Court unseal them, with only those redactions necessary to protect the identities of jurors, to the extent they have not already been disclosed. We also ask that this Court make clear that any subsequent briefs and exhibits filed in conjunction with this motion should not be filed under seal and with only those redactions necessary to protect jurors' identities.\n\nAs the Court knows, both sets of sealed records bear on allegations of juror misconduct. On January 5, 2022, the parties wrote to this Court regarding public statements made by one juror, identified as \"Juror 50,\" about how his jury room disclosure that he was a victim of sexual assault\n\n1 The right of access is an affirmative enforceable public right, and it is well-established that the press has standing to enforce this right. See, e.g., Globe Newspaper Co. v. Superior Ct. for Norfolk City, 457 U.S. 596, 609 n.25 (1982); Hartford Courant Co. v. Pellegrino, 380 F.3d 83, 91 (2d Cir. 2004).\n\nUSDC SDNY\nDOCUMENT\nELECTRONICALLY FILED\nDOC #:\nDATE FILED: 6/29/22\n\nThe motion to unseal the questionnaires of the twelve seated jurors is GRANTED. The motion to unseal the Defendant's motion for a new trial is moot as the Defendant's motion for a new trial is docketed at Dkt. No. 613.\n\nSO ORDERED.\n\nAlison J. Nathan\n6/29/22\n\nDOI-OGR-00010754",
  "text_blocks": [
    {
      "type": "printed",
      "content": "The New York Times Company",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "David McCraw\nSenior Vice President &\nDeputy General Counsel\nT 212 556 4031\nmccraw@nytimes.com\n620 8th Avenue\nNew York, NY 10018\nnytimes.com",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "January 24, 2022",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "VIA EMAIL AND FEDEX",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\nUnited States Courthouse\n40 Foley Square\nNew York, NY 10007",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Re: United States v. Maxwell, No. 20-cr-00330 (AJN) - Unsealing of Defendant's Motion for a New Trial and Questionnaires of Seated Jurors",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Dear Judge Nathan:",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "I write on behalf of The New York Times Company (\"The Times\") to request that the Court unseal (a) Defendant's Motion for a New Trial and accompanying brief and exhibits (Dkt. 580) and (b) the filled-out questionnaires for the twelve seated jurors. These records are subject to both First Amendment and common law rights of access, which set stringent standards for sealing.1 We ask that the Court unseal them, with only those redactions necessary to protect the identities of jurors, to the extent they have not already been disclosed. We also ask that this Court make clear that any subsequent briefs and exhibits filed in conjunction with this motion should not be filed under seal and with only those redactions necessary to protect jurors' identities.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "As the Court knows, both sets of sealed records bear on allegations of juror misconduct. On January 5, 2022, the parties wrote to this Court regarding public statements made by one juror, identified as \"Juror 50,\" about how his jury room disclosure that he was a victim of sexual assault",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "1 The right of access is an affirmative enforceable public right, and it is well-established that the press has standing to enforce this right. See, e.g., Globe Newspaper Co. v. Superior Ct. for Norfolk City, 457 U.S. 596, 609 n.25 (1982); Hartford Courant Co. v. Pellegrino, 380 F.3d 83, 91 (2d Cir. 2004).",
      "position": "middle"
    },
    {
      "type": "stamp",
      "content": "USDC SDNY\nDOCUMENT\nELECTRONICALLY FILED\nDOC #:\nDATE FILED: 6/29/22",
      "position": "margin"
    },
    {
      "type": "printed",
      "content": "The motion to unseal the questionnaires of the twelve seated jurors is GRANTED. The motion to unseal the Defendant's motion for a new trial is moot as the Defendant's motion for a new trial is docketed at Dkt. No. 613.",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "SO ORDERED.",
      "position": "bottom"
    },
    {
      "type": "signature",
      "content": "Alison J. Nathan",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "6/29/22",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "DOI-OGR-00010754",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "David McCraw",
      "Alison J. Nathan",
      "Juror 50"
    ],
    "organizations": [
      "The New York Times Company",
      "United States District Court",
      "Southern District of New York"
    ],
    "locations": [
      "New York",
      "NY",
      "United States"
    ],
    "dates": [
      "January 24, 2022",
      "January 5, 2022",
      "6/29/22",
      "1982",
      "2004"
    ],
    "reference_numbers": [
      "20-cr-00330",
      "Dkt. 580",
      "Dkt. No. 613",
      "DOI-OGR-00010754"
    ]
  },
  "additional_notes": "The document is a letter from David McCraw of The New York Times Company to Judge Alison J. Nathan regarding the unsealing of certain documents in the case United States v. Maxwell. The letter is dated January 24, 2022, and includes a stamped notation indicating that it was electronically filed on June 29, 2022. The document contains handwritten signature of Judge Alison J. Nathan."
}