mirror-epstein-docs/results/IMAGES003/DOJ-OGR-00006705.json

{
  "document_metadata": {
    "page_number": "2",
    "document_number": "451",
    "date": "11/12/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 451 Filed 11/12/21 Page 2 of 5\n\nFor further example, in Docket No. 387, all exhibits are withheld and the expected testimony of already anonymized Minor Victim-3 is redacted.\n\nIn Docket No. 382, Exhibits A through D, F, H and I are all withheld in full, and large portions of even the table of contests are redacted. How is the public to access the basis for withholding, when even the titles / subjects are withheld?\n\nThe First Amendment to the U.S. Constitution guarantees to the public a right of access to court proceedings. U.S. CONST. AMEND. I; Globe Newspaper Co. v. Superior Court, 457 U.S. 596, 603 (1982). The public's right of access is strongest when it comes to criminal proceedings such as these, which are matters of the \"high[est] concern and importance to the people.\" Richmond Newspapers, Inc. v. Virginia, 448 U.S. 555, 575 (1980) (plurality opinion).\n\nIf deemed necessary, PLEASE TAKE NOTICE that Inner City Press and its undersigned reporter, in personal capacity, will move this Court before Honorable Alison J. Nathan, U.S. District Judge for the Southern District of New York, at a date and time directed by the Court, for entry of an order granting permission to the heard on unsealing the improperly redacted submission in this case, on public access to trial exhibits and to the provision of access, during COVID-19 and beyond, by listen-only audio line.\n\nNon-parties such as Inner City Press and myself have standing to intervene in criminal proceedings to assert the public's right of access. United States v. Aref, 533 F.3d 72, 81 (2d Cir. 2008).\n\nPlease confirm receipt and docket this timely responsive filing, making Inner City Press an Interested Party, and thank you for your attention to it as you make logistical arrangements for the trial.\n\nRespectfully submitted,\n\nMatthew Russell Lee, Inner City Press\n\ncc: Alison.Moe@usdoj.gov, maurene.comey@usdoj.gov, bc@sternheimlaw.com, bcsternheim@mac.com, ceverdell@cohengresser.com\n\n2\nDOJ-OGR-00006705",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 451 Filed 11/12/21 Page 2 of 5",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "For further example, in Docket No. 387, all exhibits are withheld and the expected testimony of already anonymized Minor Victim-3 is redacted.\n\nIn Docket No. 382, Exhibits A through D, F, H and I are all withheld in full, and large portions of even the table of contests are redacted. How is the public to access the basis for withholding, when even the titles / subjects are withheld?\n\nThe First Amendment to the U.S. Constitution guarantees to the public a right of access to court proceedings. U.S. CONST. AMEND. I; Globe Newspaper Co. v. Superior Court, 457 U.S. 596, 603 (1982). The public's right of access is strongest when it comes to criminal proceedings such as these, which are matters of the \"high[est] concern and importance to the people.\" Richmond Newspapers, Inc. v. Virginia, 448 U.S. 555, 575 (1980) (plurality opinion).\n\nIf deemed necessary, PLEASE TAKE NOTICE that Inner City Press and its undersigned reporter, in personal capacity, will move this Court before Honorable Alison J. Nathan, U.S. District Judge for the Southern District of New York, at a date and time directed by the Court, for entry of an order granting permission to the heard on unsealing the improperly redacted submission in this case, on public access to trial exhibits and to the provision of access, during COVID-19 and beyond, by listen-only audio line.\n\nNon-parties such as Inner City Press and myself have standing to intervene in criminal proceedings to assert the public's right of access. United States v. Aref, 533 F.3d 72, 81 (2d Cir. 2008).\n\nPlease confirm receipt and docket this timely responsive filing, making Inner City Press an Interested Party, and thank you for your attention to it as you make logistical arrangements for the trial.\n\nRespectfully submitted,\n\nMatthew Russell Lee, Inner City Press\n\ncc: Alison.Moe@usdoj.gov, maurene.comey@usdoj.gov, bc@sternheimlaw.com, bcsternheim@mac.com, ceverdell@cohengresser.com",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "2",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00006705",
      "position": "footer"
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  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Matthew Russell Lee",
      "Alison.Moe@usdoj.gov",
      "maurene.comey@usdoj.gov",
      "bc@sternheimlaw.com",
      "bcsternheim@mac.com",
      "ceverdell@cohengresser.com"
    ],
    "organizations": [
      "Inner City Press",
      "U.S. District Judge for the Southern District of New York",
      "Globe Newspaper Co.",
      "Superior Court",
      "Richmond Newspapers, Inc.",
      "United States"
    ],
    "locations": [
      "New York"
    ],
    "dates": [
      "11/12/21",
      "1982",
      "1980",
      "2008"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 451",
      "Docket No. 387",
      "Docket No. 382",
      "457 U.S. 596",
      "448 U.S. 555",
      "533 F.3d 72",
      "DOJ-OGR-00006705"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case, discussing issues of public access to court proceedings and exhibits. The text is mostly printed, with no handwritten content or stamps visible. The document is well-formatted and legible."
}