{
  "document_metadata": {
    "page_number": "1 of 2",
    "document_number": "359",
    "date": "10/18/21",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 359 Filed 10/18/21 Page 1 of 2\nU.S. Department of Justice\nUnited States Attorney\nSouthern District of New York\nThe Silvio J. Mollo Building\nOne Saint Andrew's Plaza\nNew York, New York 10007\nOctober 18, 2021\nBY ECF\nThe Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\nUnited States Courthouse\n40 Foley Square\nNew York, New York 10007\nRe: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)\nDear Judge Nathan:\nThe Government respectfully submits its motions in limine, which the Government is submitting to the Court under seal by email with proposed redactions. The Government's proposed redactions are 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 Government's motions in limine are judicial documents subject to the common law presumption of access, the proposed redactions are narrowly tailored to protect the privacy interests of victims—including victims who have not identified themselves on the record in this case and who have not publicly identified themselves as victims referenced in the Indictment in this case—and third parties referenced in the document.\nIn addition, the Government seeks redaction of Section X at least until the conclusion of trial. Additional justification for this sealing request is located in footnote 11 on page 49 of the Government's motions in limine.\nDOJ-OGR-00005264",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 359 Filed 10/18/21 Page 1 of 2",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "U.S. Department of Justice\nUnited States Attorney\nSouthern District of New York\nThe Silvio J. Mollo Building\nOne Saint Andrew's Plaza\nNew York, New York 10007",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "October 18, 2021",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "BY ECF",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\nUnited States Courthouse\n40 Foley Square\nNew York, New York 10007",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Dear Judge Nathan:\nThe Government respectfully submits its motions in limine, which the Government is submitting to the Court under seal by email with proposed redactions. The Government's proposed redactions are 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 Government's motions in limine are judicial documents subject to the common law presumption of access, the proposed redactions are narrowly tailored to protect the privacy interests of victims—including victims who have not identified themselves on the record in this case and who have not publicly identified themselves as victims referenced in the Indictment in this case—and third parties referenced in the document.\nIn addition, the Government seeks redaction of Section X at least until the conclusion of trial. Additional justification for this sealing request is located in footnote 11 on page 49 of the Government's motions in limine.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00005264",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ghislaine Maxwell"
    ],
    "organizations": [
      "U.S. Department of Justice",
      "United States Attorney",
      "United States District Court",
      "Second Circuit"
    ],
    "locations": [
      "New York",
      "Onondaga"
    ],
    "dates": [
      "October 18, 2021",
      "2006"
    ],
    "reference_numbers": [
      "20 Cr. 330 (AJN)",
      "Case 1:20-cr-00330-PAE",
      "Document 359",
      "DOJ-OGR-00005264"
    ]
  },
  "additional_notes": "The document appears to be a formal letter from the U.S. Department of Justice to the Honorable Alison J. Nathan regarding the case United States v. Ghislaine Maxwell. The letter discusses the government's motions in limine and proposed redactions. The document is well-formatted and free of significant damage or redactions."
}