mirror-epstein-docs/results/IMAGES004/DOJ-OGR-00009843.json

{
  "document_metadata": {
    "page_number": "45",
    "document_number": "643",
    "date": "03/11/22",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 643 Filed 03/11/22 Page 45 of 49\n\ninto the subject, by allowing [him] an opportunity to fully and fairly brief the Court on the relevant issues.\" (Id. at 7).\n\nIn his motion, Juror 50's counsel requested a copy of Juror 50's questionnaire, as well as the transcript of his testimony during voir dire. (Juror 50 Mem. at 4). The defendant opposes Juror 50's request, describing it as a \"discovery request\" and claiming that the release of Juror 50's questionnaire would prejudice the \"investigation\" of Juror 50's \"conduct\" and \"undoubtedly color Juror No. 50's testimony and allow him to place himself in the best possible posture.\" (Def. Mem. at 52-53). As an initial matter, the Government notes that Juror 50's voir dire was conducted in open court and is therefore available to Juror 50 and his counsel. As to the request for his questionnaire, the Government submits that Juror 50 should get a copy of his own questionnaire.\n\nThe defendant has characterized Juror 50's request for his own questionnaire as a \"discovery request,\" but Juror 50 is not a defendant and he is not seeking discovery.18 He is asking for access to his questionnaire: a document that he himself prepared and swore under penalty of perjury, and which, now that trial is complete, is maintained under seal principally if not entirely to protect his own privacy interests. See, e.g., Press-Enter. Co. v. Superior Ct. of California, Riverside Cty., 464 U.S. 501, 511-12 (1984). The privacy concerns that otherwise might require limiting access to Juror 50's questionnaire plainly do not apply to Juror 50 himself or his counsel.19\n\n18 The defendant claims that courts have \"refused discovery to individuals or entities under investigation\" \"[u]nder analogous circumstances.\" (Def. Mem. at 53). But in support of that argument, the defendant cites only John Doe Agency v. John Doe Corp., 493 U.S. 146 (1989), which is clearly not analogous as it involved a request under the Freedom of Information Act and an ongoing grand jury proceeding.\n19 On January 24, 2022, the New York Times Company moved to unseal, among other things, the filled-out questionnaires for the twelve seated jurors. (Dkt. No. 583). The Government intends to address that motion on or before February 11, 2022 in accordance with the Court's January 26, 2022 order (Dkt. No. 585).\n\n43",
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      "content": "Case 1:20-cr-00330-PAE Document 643 Filed 03/11/22 Page 45 of 49",
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      "type": "printed",
      "content": "into the subject, by allowing [him] an opportunity to fully and fairly brief the Court on the relevant issues.\" (Id. at 7).\n\nIn his motion, Juror 50's counsel requested a copy of Juror 50's questionnaire, as well as the transcript of his testimony during voir dire. (Juror 50 Mem. at 4). The defendant opposes Juror 50's request, describing it as a \"discovery request\" and claiming that the release of Juror 50's questionnaire would prejudice the \"investigation\" of Juror 50's \"conduct\" and \"undoubtedly color Juror No. 50's testimony and allow him to place himself in the best possible posture.\" (Def. Mem. at 52-53). As an initial matter, the Government notes that Juror 50's voir dire was conducted in open court and is therefore available to Juror 50 and his counsel. As to the request for his questionnaire, the Government submits that Juror 50 should get a copy of his own questionnaire.",
      "position": "top"
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    {
      "type": "printed",
      "content": "The defendant has characterized Juror 50's request for his own questionnaire as a \"discovery request,\" but Juror 50 is not a defendant and he is not seeking discovery.18 He is asking for access to his questionnaire: a document that he himself prepared and swore under penalty of perjury, and which, now that trial is complete, is maintained under seal principally if not entirely to protect his own privacy interests. See, e.g., Press-Enter. Co. v. Superior Ct. of California, Riverside Cty., 464 U.S. 501, 511-12 (1984). The privacy concerns that otherwise might require limiting access to Juror 50's questionnaire plainly do not apply to Juror 50 himself or his counsel.19",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "18 The defendant claims that courts have \"refused discovery to individuals or entities under investigation\" \"[u]nder analogous circumstances.\" (Def. Mem. at 53). But in support of that argument, the defendant cites only John Doe Agency v. John Doe Corp., 493 U.S. 146 (1989), which is clearly not analogous as it involved a request under the Freedom of Information Act and an ongoing grand jury proceeding.\n19 On January 24, 2022, the New York Times Company moved to unseal, among other things, the filled-out questionnaires for the twelve seated jurors. (Dkt. No. 583). The Government intends to address that motion on or before February 11, 2022 in accordance with the Court's January 26, 2022 order (Dkt. No. 585).",
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      "content": "43",
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  ],
  "entities": {
    "people": [],
    "organizations": [
      "New York Times Company"
    ],
    "locations": [
      "California",
      "Riverside Cty."
    ],
    "dates": [
      "January 24, 2022",
      "February 11, 2022",
      "January 26, 2022",
      "03/11/22"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "643",
      "Dkt. No. 583",
      "Dkt. No. 585",
      "464 U.S. 501",
      "493 U.S. 146"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case, with a clear and legible format. There are no visible redactions or damage to the document."
}