DOJ-OGR-00008441.jpg
691 KB
Extraction Summary
5
People
4
Organizations
1
Locations
2
Events
2
Relationships
0
Quotes
Document Information
Type:
Legal document
File Size:
691 KB
Summary
This legal document, part of a court filing, outlines a joint proposal from the prosecution and defense regarding the presentation of closing arguments. The parties argue that alternatives like toggling monitors or using printed binders for the jury are unworkable due to potential interruptions, logistical difficulties, and the risk of inadvertently exposing sealed material, which would violate the privacy of victims and third parties. They propose instead to provide redacted copies of their presentation slides to the public on the following day.
People (5)
| Name | Role | Context |
|---|---|---|
| jurors | Jury member |
Mentioned in the context of viewing presentations during closing arguments, either on monitors or in printed binders.
|
| court staff | Court employee |
Mentioned as being responsible for turning monitors on and off, and as a potential source of human error that could l...
|
| victims | Victim |
Their privacy interests are cited as a reason to avoid displaying sealed material publicly.
|
| third parties | Third party |
Their privacy interests are cited as a reason to avoid displaying sealed material publicly.
|
| counsel | Legal counsel |
Mentioned in the context of finding it difficult to ensure jurors are following along with printed materials during c...
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| The Court | Judicial body |
Mentioned as having likely observed jurors' behavior with paper materials during the trial.
|
| The Government | Government agency |
One of the parties in the case, presenting a closing argument to which the defense may wish to respond.
|
| The Defense | Legal team |
One of the parties in the case, who wishes to retain the ability to adjust their slides in response to the Government...
|
| DOJ | Government agency |
Inferred from the Bates number 'DOJ-OGR-00008441' in the document footer, indicating the Department of Justice.
|
Timeline (2 events)
Locations (1)
| Location | Context |
|---|---|
|
Mentioned in relation to courthouse staff, whose error could result in the publication of sealed material.
|
Relationships (2)
The document describes them as opposing sides in a legal case, with the defense wanting to respond to the Government's closing argument.
The parties are jointly making a proposal to the Court regarding the logistics of the closing arguments, indicating a cooperative effort to resolve a procedural issue.
Full Extracted Text
Complete text extracted from the document (2,061 characters)
Case 1:20-cr-00330-PAE Document 558 Filed 12/19/21 Page 3 of 5
Second, the parties believe that either alternative would interfere with the parties’ ability to present their case to the jury and advocate effectively for their clients. Whether the interruption is caused by the need for the jurors to find a page in their binders or for court staff to turn monitors on and off, the interruption would have a significant and detrimental effect on the ability of the parties to present their case efficiently and effectively to the jury. Given the significance of closing argument to the parties’ presentations to the jury, this interference undermines the parties’ core interests.
Finally, and specifically with regard to toggling screens on and off, presenting slides to the jury and the public that contain sealed material poses risks to the privacy interests of victims and third parties. If a screen remains active through natural human error—on the part of the parties or the courthouse staff—it would result in the publicization of sealed material.
For those reasons, the parties believe that the use of binders or toggling screens during closing argument is unworkable. The parties also considered giving the jurors printed versions of their presentations in lieu of binders. Doing so is unworkable for two reasons. First, as the Court also likely observed during trial, jurors move at different rates through the paper material placed before them. It will be difficult for counsel to ensure that no jurors are falling behind or moving ahead during the closing arguments. Second, to the extent the defense would like to adjust their slides in response to the Government’s closing argument, that ability is compromised if the defense must also have their slides printed for the jury immediately upon the conclusion of the Government’s argument.
Accordingly, the parties propose that they will provide a copy of their slides, without any sealed material, to the public tomorrow as soon as the parties have had adequate time to review
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DOJ-OGR-00008441
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