DOJ-OGR-00018360.pdf

Case 1:20-cr-00330-PAE Document 751 Filed 08/10/22 Page 23 of 261 1163 LC6Cmax1 them against other public records, which are unredacted and have Jane's identifiers. So the redactions we would propose would be substantial and perhaps beyond recognition in order to avoid that problem. For example, in a civil case in this district, if you were print out from ECF the full docket entry and it were a public document that had identifiers for the person who filed that civil suit, in order to redact it to make sure someone couldn't troll around PACER and find the public version, you would have to redact essentially everything, and that's the problem here. The same is true for the copy -- THE COURT: Please just take a look, see if there is an agreement that you'll propose to me, taking into account also what is already public regarding the document in the trial transcript. So, one of the lessons, too, is that simply you can't just look in isolation. So if information is already public, then redacting it -- but you'll look and see if there is some appropriate middle ground that would ensure the continued privacy of the witness consistent with the law. MS. MOE: Yes, your Honor. Thank you. THE COURT: Thank you. And we have all of our jurors. Everybody ready? Okay. We'll bring them in. MR. ROHRBACH: Your Honor, we need just a minute or two to print and sign the stipulation. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00018360