mirror-epstein-docs/results/IMAGES004/DOJ-OGR-00008969.json

{
  "document_metadata": {
    "page_number": "4",
    "document_number": "604",
    "date": "02/17/22",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 604 Filed 02/17/22 Page 4 of 6\n\nthat create teachings moments about the importance of safeguarding rights that not only affect notorious and unpopular defendants but potentially affect the rest of us as well. We believe this case is such a moment, and that we can add a perspective that goes beyond the interests of one defendant.\n\n8. The Supreme Court has taught that the approach followed by this Court in this high-profile case of using a juror questionnaire and following up with voir dire can be highly effective. See Skilling v. United States, 561 U.S. 358, 384 (2010) (“Although the widespread community impact necessitated careful identification and inspection of prospective jurors’ connections to Enron, the extensive screening questionnaire and follow up voir dire were well suited to that task.”) But the success of this approach in weeding out juror bias presupposes that jurors will answer the questions posed by the Court honestly and accurately. Because this Court’s decision on how to proceed will have far-ranging implications for other cases in which questions concerning the accuracy of a juror’s answers arises, NACDL would like to share its suggestions and concerns with the Court for how to devise a fair framework for addressing and deciding this issue.\n\n9. “Federal courts have discretion to permit participation of amici where such participation will not prejudice any party and may be of assistance to the court.” Strougo v. Scudder, Stevens & Clark, Inc., 1997 WL 473566 (S.D.N.Y. Aug. 18, 1997) (citing Vulcan Soc’y of NYC Fire Dep’t, Inc. v. Civil Serv. Comm’n, 490 F.2d 387, 391 (2d Cir. 1973)); see also Auto Club of NY, Inc. v Port Auth. Of New York, 2011 WL 5865296, at *1 (S.D.N.Y. Nov. 22, 2011) (“The usual rationale for amicus curiae submissions is that they are of aid to the court and offer insights not available from the parties.”) Most recently, Judge Caproni granted NACDL\n\n4\n\nDOJ-OGR-00008969",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 604 Filed 02/17/22 Page 4 of 6",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "that create teachings moments about the importance of safeguarding rights that not only affect notorious and unpopular defendants but potentially affect the rest of us as well. We believe this case is such a moment, and that we can add a perspective that goes beyond the interests of one defendant.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "8. The Supreme Court has taught that the approach followed by this Court in this high-profile case of using a juror questionnaire and following up with voir dire can be highly effective. See Skilling v. United States, 561 U.S. 358, 384 (2010) (“Although the widespread community impact necessitated careful identification and inspection of prospective jurors’ connections to Enron, the extensive screening questionnaire and follow up voir dire were well suited to that task.”) But the success of this approach in weeding out juror bias presupposes that jurors will answer the questions posed by the Court honestly and accurately. Because this Court’s decision on how to proceed will have far-ranging implications for other cases in which questions concerning the accuracy of a juror’s answers arises, NACDL would like to share its suggestions and concerns with the Court for how to devise a fair framework for addressing and deciding this issue.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "9. “Federal courts have discretion to permit participation of amici where such participation will not prejudice any party and may be of assistance to the court.” Strougo v. Scudder, Stevens & Clark, Inc., 1997 WL 473566 (S.D.N.Y. Aug. 18, 1997) (citing Vulcan Soc’y of NYC Fire Dep’t, Inc. v. Civil Serv. Comm’n, 490 F.2d 387, 391 (2d Cir. 1973)); see also Auto Club of NY, Inc. v Port Auth. Of New York, 2011 WL 5865296, at *1 (S.D.N.Y. Nov. 22, 2011) (“The usual rationale for amicus curiae submissions is that they are of aid to the court and offer insights not available from the parties.”) Most recently, Judge Caproni granted NACDL",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "4",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00008969",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Judge Caproni"
    ],
    "organizations": [
      "NACDL",
      "Enron",
      "Supreme Court",
      "Auto Club of NY, Inc.",
      "Port Auth. Of New York",
      "Vulcan Soc’y of NYC Fire Dep’t, Inc.",
      "Civil Serv. Comm’n"
    ],
    "locations": [
      "New York"
    ],
    "dates": [
      "02/17/22",
      "Aug. 18, 1997",
      "Nov. 22, 2011"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 604",
      "561 U.S. 358",
      "1997 WL 473566",
      "490 F.2d 387",
      "2011 WL 5865296",
      "DOJ-OGR-00008969"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a high-profile case. The text is well-formatted and printed, with no visible handwriting or stamps. The document includes citations to various court cases and references to specific court decisions."
}