mirror-epstein-docs/results/IMAGES003/DOJ-OGR-00008168.json

{
  "document_metadata": {
    "page_number": "3",
    "document_number": "511",
    "date": "11/27/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 511 Filed 11/27/21 Page 3 of 3 included in the 3500 material or the government exhibits, we will provide paper copies of those documents to the government before we show them to the witness on the witness screen. We have conferred with the government, and they do not agree to the proposed procedure. Among other things, they expressed concern that a juror might see the witness screen. But the jurors are permitted to know the identity of the witnesses testifying under pseudonyms, so that concern seems unjustified to the defense. We believe this process will adequately safeguard everyone's interests and provide for a more efficient trial. We respectfully ask the Court to approve this procedure. Very truly yours. /s/ BOBBI C. STERNHEIM cc: All Counsel of Record DOJ-OGR-00008168",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 511 Filed 11/27/21 Page 3 of 3",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "included in the 3500 material or the government exhibits, we will provide paper copies of those documents to the government before we show them to the witness on the witness screen. We have conferred with the government, and they do not agree to the proposed procedure. Among other things, they expressed concern that a juror might see the witness screen. But the jurors are permitted to know the identity of the witnesses testifying under pseudonyms, so that concern seems unjustified to the defense. We believe this process will adequately safeguard everyone's interests and provide for a more efficient trial. We respectfully ask the Court to approve this procedure.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Very truly yours.",
      "position": "middle"
    },
    {
      "type": "signature",
      "content": "/s/ BOBBI C. STERNHEIM",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "cc: All Counsel of Record",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00008168",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "BOBBI C. STERNHEIM"
    ],
    "organizations": [],
    "locations": [],
    "dates": [
      "11/27/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "511",
      "DOJ-OGR-00008168"
    ]
  },
  "additional_notes": "The document appears to be a court filing with a clear and legible format. There are no visible redactions or damage."
}