mirror-epstein-docs/results/IMAGES002/DOJ-OGR-00003964.json

{
  "document_metadata": {
    "page_number": "2",
    "document_number": "241",
    "date": "04/23/21",
    "document_type": "court document",
    "has_handwriting": true,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 241 Filed 04/23/21 Page 2 of 2\nPage 2\nproposed redactions are narrowly tailored to protect the privacy interests of third parties referenced in the documents. These redactions are thus consistent with similar, tailored redactions permitted by the Court in this case to protect the privacy interests of third parties. Accordingly, the Government respectfully requests that the Court adopt the proposed redactions.\nThe Government has conferred with defense counsel and counsel from BSF, both of whom indicated that they take no position on the Government's redaction requests.\nRespectfully submitted,\nAUDREY STRAUSS\nUnited States Attorney\nBy:\nMaurene Comey\nAlison Moe\nLara Pomerantz\nAndrew Rohrbach\nAssistant United States Attorneys\nSouthern District of New York\n212-637-2324\nCc: All Counsel of Record (By ECF)\nThe Court grants the Government's redaction requests. Its conclusion is guided by the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Under this test, the Court must: (i) determine whether the documents in question are \"judicial documents;\" (ii) assess the weight of the common law presumption of access to the materials; and (iii) balance competing considerations against the presumption of access. Id. at 119-20.\nThe Court concludes that these are judicial documents and that the First Amendment and common law presumptions of access attach. But in balancing competing considerations against the presumption of access, the Court finds that the specific arguments the Government has put forward in this letter, including the need to protect the privacy interests of third parties referenced in the documents, favor the narrowly tailored redactions. See United States v. Amodeo, 71 F.3d 1044, 1050 (2d Cir. 1995).\nThe Defendant and Boies Schiller are hereby ORDERED to docket the respective documents with the Government's proposed redactions by April 23, 2021.\nSO ORDERED.\nDOJ-OGR-00003964",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 241 Filed 04/23/21 Page 2 of 2",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "proposed redactions are narrowly tailored to protect the privacy interests of third parties referenced in the documents. These redactions are thus consistent with similar, tailored redactions permitted by the Court in this case to protect the privacy interests of third parties. Accordingly, the Government respectfully requests that the Court adopt the proposed redactions.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The Government has conferred with defense counsel and counsel from BSF, both of whom indicated that they take no position on the Government's redaction requests.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Respectfully submitted,\nAUDREY STRAUSS\nUnited States Attorney\nBy:\nMaurene Comey\nAlison Moe\nLara Pomerantz\nAndrew Rohrbach\nAssistant United States Attorneys\nSouthern District of New York\n212-637-2324",
      "position": "middle"
    },
    {
      "type": "handwritten",
      "content": "Alison J. Nathan",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Cc: All Counsel of Record (By ECF)",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The Court grants the Government's redaction requests. Its conclusion is guided by the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Under this test, the Court must: (i) determine whether the documents in question are \"judicial documents;\" (ii) assess the weight of the common law presumption of access to the materials; and (iii) balance competing considerations against the presumption of access. Id. at 119-20.",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "The Court concludes that these are judicial documents and that the First Amendment and common law presumptions of access attach. But in balancing competing considerations against the presumption of access, the Court finds that the specific arguments the Government has put forward in this letter, including the need to protect the privacy interests of third parties referenced in the documents, favor the narrowly tailored redactions. See United States v. Amodeo, 71 F.3d 1044, 1050 (2d Cir. 1995).",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "The Defendant and Boies Schiller are hereby ORDERED to docket the respective documents with the Government's proposed redactions by April 23, 2021.\nSO ORDERED.",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00003964",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Audrey Strauss",
      "Maurene Comey",
      "Alison Moe",
      "Lara Pomerantz",
      "Andrew Rohrbach",
      "Alison J. Nathan"
    ],
    "organizations": [
      "United States Attorney",
      "Southern District of New York",
      "Boies Schiller"
    ],
    "locations": [
      "New York"
    ],
    "dates": [
      "04/23/21",
      "April 23, 2021"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 241",
      "DOJ-OGR-00003964"
    ]
  },
  "additional_notes": "The document appears to be a court filing with a signature from Alison J. Nathan, U.S.D.J. The document is well-formatted and legible."
}