mirror-epstein-docs/results/IMAGES004/DOJ-OGR-00011237.json

{
  "document_metadata": {
    "page_number": "5",
    "document_number": "704",
    "date": "07/12/22",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 704 Filed 07/12/22 Page 5 of 8 stake in the manner of other victims, and testifying under her true name will not chill the decision of other victims to come forward. The defendant can hardly invoke the Crime Victims' Rights Act to say Healy is a victim for purposes of her pseudonym motion, just so Healy can take the stand and say she is not a victim. With respect to , the defendant argues this witness is entitled to privacy protection as . (Def. Letter at 3). The defendant has not produced any Rule 26.2 disclosures regarding so the Government has very limited information regarding her identity and no information about her expected testimony. But it does not appear from the defendant's letter that her testimony will concern anything sensitive. Nor does it appear that . It is not clear then why revelation of \"true name could impact her security and professional responsibilities\" . (Def. Letter at 4). The Government's case agents, whose identities are no secret at this trial, . The defendant also argues that employment will be \"compromised by the revealing of her testimony in this case.\" (Def. Letter at 4-5). But the cases the defendant cites do not stand for the broad proposition that . (Def. Letter at 5). Those cases involve undercover officers or CIA officers, for whom public association with law enforcement at all would render them unable to do their job and pose safety concerns. See, e.g., United States v. Alimehmeti, 284 F. Supp. 3d 477, 490-91 (S.D.N.Y. 2018) (\"This Court has approved pseudonymous testimony by a UC as a means of protecting a UC's safety and ability to continue to work as such, as have other courts.\" (citations omitted)). Here, 5 DOJ-OGR-00011237",
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      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 704 Filed 07/12/22 Page 5 of 8",
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    {
      "type": "printed",
      "content": "stake in the manner of other victims, and testifying under her true name will not chill the decision of other victims to come forward. The defendant can hardly invoke the Crime Victims' Rights Act to say Healy is a victim for purposes of her pseudonym motion, just so Healy can take the stand and say she is not a victim.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "With respect to , the defendant argues this witness is entitled to privacy protection as . (Def. Letter at 3). The defendant has not produced any Rule 26.2 disclosures regarding so the Government has very limited information regarding her identity and no information about her expected testimony. But it does not appear from the defendant's letter that her testimony will concern anything sensitive. Nor does it appear that . It is not clear then why revelation of \"true name could impact her security and professional responsibilities\" . (Def. Letter at 4). The Government's case agents, whose identities are no secret at this trial, .",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The defendant also argues that employment will be \"compromised by the revealing of her testimony in this case.\" (Def. Letter at 4-5). But the cases the defendant cites do not stand for the broad proposition that . (Def. Letter at 5). Those cases involve undercover officers or CIA officers, for whom public association with law enforcement at all would render them unable to do their job and pose safety concerns. See, e.g., United States v. Alimehmeti, 284 F. Supp. 3d 477, 490-91 (S.D.N.Y. 2018) (\"This Court has approved pseudonymous testimony by a UC as a means of protecting a UC's safety and ability to continue to work as such, as have other courts.\" (citations omitted)). Here,",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "5",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00011237",
      "position": "footer"
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  ],
  "entities": {
    "people": [
      "Healy"
    ],
    "organizations": [
      "CIA"
    ],
    "locations": [
      "S.D.N.Y."
    ],
    "dates": [
      "07/12/22",
      "2018"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "704",
      "284 F. Supp. 3d 477",
      "DOJ-OGR-00011237"
    ]
  },
  "additional_notes": "The document appears to be a court filing with redactions. The text is mostly clear, but some information is blacked out."
}