mirror-epstein-docs/results/IMAGES006/DOJ-OGR-00015061.json

{
  "document_metadata": {
    "page_number": "4",
    "document_number": "795",
    "date": "07/25/25",
    "document_type": "Court Document",
    "has_handwriting": true,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 795 Filed 07/25/25 Page 4 of 4\n\nquestion best left to the court adjudicating that future case. We are concerned that, if this Court explicitly or implicitly blesscs the Government's proposed redactions of non-victim-related personally identifiable information (even in passing), that opinion will be treated as a proverbial thumb on the scale in our FOIA case without materially affecting the Court's decision in this case.\n\nIn other words, if this Court mentions in its decision that it was swayed at all by the Government's promise to redact personally identifiable information, we are concerned that the Government will then argue in its FOIA case that \"Judge Englemayer agreed that this information should not be publicly disclosed.\" Therefore, we respectfully request that this Court not take the Government's statements regarding non-victim-related personally identifiable information into account when reaching its decision regarding the Government's motion, and we further request that the Court specify that it is not opining on that question, should it grant the Government's motion.\n\nThe Government takes no position on the intervention of MSW Media. I attempted twice—Wednesday and Thursday—to reach Defendant's counsel and have not received a response, so I am filing this as an opposed motion due to the fast-moving nature of this case.\n\nSincerely,\n\nKel McClanahan\nCounsel for Proposed Intervenor\n\nDOJ-OGR-00015061",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 795 Filed 07/25/25 Page 4 of 4",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "question best left to the court adjudicating that future case. We are concerned that, if this Court explicitly or implicitly blesscs the Government's proposed redactions of non-victim-related personally identifiable information (even in passing), that opinion will be treated as a proverbial thumb on the scale in our FOIA case without materially affecting the Court's decision in this case.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "In other words, if this Court mentions in its decision that it was swayed at all by the Government's promise to redact personally identifiable information, we are concerned that the Government will then argue in its FOIA case that \"Judge Englemayer agreed that this information should not be publicly disclosed.\" Therefore, we respectfully request that this Court not take the Government's statements regarding non-victim-related personally identifiable information into account when reaching its decision regarding the Government's motion, and we further request that the Court specify that it is not opining on that question, should it grant the Government's motion.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The Government takes no position on the intervention of MSW Media. I attempted twice—Wednesday and Thursday—to reach Defendant's counsel and have not received a response, so I am filing this as an opposed motion due to the fast-moving nature of this case.",
      "position": "middle"
    },
    {
      "type": "handwritten",
      "content": "Kel McClanahan",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "Sincerely,\nKel McClanahan\nCounsel for Proposed Intervenor",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00015061",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Kel McClanahan",
      "Englemayer"
    ],
    "organizations": [
      "MSW Media",
      "Government"
    ],
    "locations": [],
    "dates": [
      "07/25/25",
      "Wednesday",
      "Thursday"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "795",
      "DOJ-OGR-00015061"
    ]
  },
  "additional_notes": "The document appears to be a court filing with a handwritten signature. The text is mostly printed, with some minor formatting issues. There are no visible redactions or damage."
}