mirror-epstein-docs/results/IMAGES001/DOJ-OGR-00002760.json

{
  "document_metadata": {
    "page_number": "2",
    "document_number": "166",
    "date": "03/15/2021",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
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  "full_text": "Case 1:20-cr-00330-AJN Document 166 Filed 03/15/21 Page 2 of 2\nThe Honorable Alison J. Nathan\nMarch 15, 2021\nPage 2\n11. Reply Memorandum in Support of Motion Under the Fourth Amendment, Martindell, and the Fifth Amendment to Suppress All Evidence Obtained from the Government's Subpoena to _______ and to Dismiss Counts Five and Six\n12. Reply Memorandum in Support of Motion to Dismiss Counts One through Four of the Superseding Indictment for Lack of Specificity\nSeveral of the reply memoranda reference or discuss Confidential Information produced in discovery and are therefore redacted pursuant to paragraph 15 of the Protective Order (Dkt. 36). In order to give the government the chance to review the proposed redactions, we will not file on the public docket any reply memoranda that contain redactions until we are instructed to do so by the Court.1\nThe remaining reply memoranda do not contain any redactions. However, we are mindful of the fact that the government's Omnibus Memorandum in Opposition to the Defendant's Pre-trial Motions, to which the reply memoranda respond, has not yet been filed on the public docket. Accordingly, we will also refrain from filing the reply memoranda that do not contain redactions on the public docket until we are instructed to do so by the Court.\nInstead, we will submit by email to the Court and the government all of the reply memoranda and exhibits pursuant to Rule 2(B) of the Court's individual rules of criminal practice. For the reply memoranda and exhibits that contain redactions, we will submit two versions - an unredacted original to be kept under seal and a version for public filing with proposed redactions.\nPlease contact us with any questions. Your consideration is greatly appreciated.\nRespectfully submitted,\n/s/ Christian R. Everdell\nChristian R. Everdell\nCOHEN & GRESSER LLP\n800 Third Avenue, 21st Floor\nNew York, New York 10022\n(212) 957-7600\ncc: All counsel of record (via email)\n1 For documents that the government has designated as \"Confidential,\" we have preliminarily indicated that they be filed under seal, as required by paragraph 15 of the Protective Order. However, because some of the exhibits are \"judicial documents,\" we intend to propose that those \"Confidential\" designations be amended consistent with our March 9, 2021 letter to the Court.\nDOJ-OGR-00002760",
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      "content": "Case 1:20-cr-00330-AJN Document 166 Filed 03/15/21 Page 2 of 2",
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    {
      "type": "printed",
      "content": "The Honorable Alison J. Nathan\nMarch 15, 2021\nPage 2",
      "position": "header"
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    {
      "type": "printed",
      "content": "11. Reply Memorandum in Support of Motion Under the Fourth Amendment, Martindell, and the Fifth Amendment to Suppress All Evidence Obtained from the Government's Subpoena to _______ and to Dismiss Counts Five and Six\n12. Reply Memorandum in Support of Motion to Dismiss Counts One through Four of the Superseding Indictment for Lack of Specificity",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Several of the reply memoranda reference or discuss Confidential Information produced in discovery and are therefore redacted pursuant to paragraph 15 of the Protective Order (Dkt. 36). In order to give the government the chance to review the proposed redactions, we will not file on the public docket any reply memoranda that contain redactions until we are instructed to do so by the Court.1",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "The remaining reply memoranda do not contain any redactions. However, we are mindful of the fact that the government's Omnibus Memorandum in Opposition to the Defendant's Pre-trial Motions, to which the reply memoranda respond, has not yet been filed on the public docket. Accordingly, we will also refrain from filing the reply memoranda that do not contain redactions on the public docket until we are instructed to do so by the Court.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Instead, we will submit by email to the Court and the government all of the reply memoranda and exhibits pursuant to Rule 2(B) of the Court's individual rules of criminal practice. For the reply memoranda and exhibits that contain redactions, we will submit two versions - an unredacted original to be kept under seal and a version for public filing with proposed redactions.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Please contact us with any questions. Your consideration is greatly appreciated.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Respectfully submitted,\n/s/ Christian R. Everdell\nChristian R. Everdell\nCOHEN & GRESSER LLP\n800 Third Avenue, 21st Floor\nNew York, New York 10022\n(212) 957-7600",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "cc: All counsel of record (via email)",
      "position": "footer"
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    {
      "type": "printed",
      "content": "1 For documents that the government has designated as \"Confidential,\" we have preliminarily indicated that they be filed under seal, as required by paragraph 15 of the Protective Order. However, because some of the exhibits are \"judicial documents,\" we intend to propose that those \"Confidential\" designations be amended consistent with our March 9, 2021 letter to the Court.",
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    {
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      "content": "DOJ-OGR-00002760",
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  "entities": {
    "people": [
      "Alison J. Nathan",
      "Christian R. Everdell"
    ],
    "organizations": [
      "COHEN & GRESSER LLP"
    ],
    "locations": [
      "New York"
    ],
    "dates": [
      "March 15, 2021",
      "March 9, 2021"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "Document 166",
      "Dkt. 36",
      "DOJ-OGR-00002760"
    ]
  },
  "additional_notes": "The document appears to be a court filing with redactions and references to confidential information. The text is mostly printed, with a signature block at the end. There are no visible stamps or handwritten notes."
}