mirror-epstein-docs/results/IMAGES002/DOJ-OGR-00004133.json

{
  "document_metadata": {
    "page_number": "2",
    "document_number": "283",
    "date": "05/14/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 283 Filed 05/14/21 Page 2 of 2\nPage 2\nAfter reviewing the defense's letter and exhibits, the Government respectfully submits that Exhibits A and B should be filed under seal. This proposal is consistent with the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Although the defense's letter and exhibits are judicial documents subject to the common law presumption of access, sealing the exhibits—each of which is only one page—is narrowly tailored to protect the privacy interests of a victim and third party implicated in the documents. The Court has accepted other exhibits under seal or in redacted form in this case to protect such privacy interests. (See, e.g., Dkt. No. 168, 232).\nRespectfully submitted,\nAUDREY STRAUSS\nUnited States Attorney\nBy: s/\nMaurene Comey\nAlison Moe\nLara Pomerantz\nAndrew Rohrbach\nAssistant United States Attorneys\nSouthern District of New York\nCc: Defense counsel (By ECF)",
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      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 283 Filed 05/14/21 Page 2 of 2",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Page 2",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "After reviewing the defense's letter and exhibits, the Government respectfully submits that Exhibits A and B should be filed under seal. This proposal is consistent with the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Although the defense's letter and exhibits are judicial documents subject to the common law presumption of access, sealing the exhibits—each of which is only one page—is narrowly tailored to protect the privacy interests of a victim and third party implicated in the documents. The Court has accepted other exhibits under seal or in redacted form in this case to protect such privacy interests. (See, e.g., Dkt. No. 168, 232).",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Respectfully submitted,",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "AUDREY STRAUSS\nUnited States Attorney",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "By: s/\nMaurene Comey\nAlison Moe\nLara Pomerantz\nAndrew Rohrbach\nAssistant United States Attorneys\nSouthern District of New York",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Cc: Defense counsel (By ECF)",
      "position": "footer"
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  ],
  "entities": {
    "people": [
      "Maurene Comey",
      "Alison Moe",
      "Lara Pomerantz",
      "Andrew Rohrbach",
      "Audrey Strauss"
    ],
    "organizations": [
      "United States Attorney",
      "Southern District of New York"
    ],
    "locations": [
      "New York"
    ],
    "dates": [
      "05/14/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "283",
      "168",
      "232",
      "435 F.3d 110"
    ]
  },
  "additional_notes": "The document appears to be a court filing with a clear and legible format. There are no visible redactions or damage to the document."
}