{
  "document_metadata": {
    "page_number": "1 of 3",
    "document_number": "53",
    "date": "09/08/20",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 53 Filed 09/08/20 Page 1 of 3 Haddon, Morgan and Foreman, P.C Jeffrey Pagliuca 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 FX 303.832.2628 www.hmflaw.com jpagliuca@hmflaw.com August 24, 2020 VIA EMAIL The Honorable Alison J. Nathan United States District Court Southern District of New York 40 Foley Square New York, NY 10007 Re: Proposed Redactions to Request to Modify Protective Order (Under Seal) United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan, In accordance with this Court's Order of August 18, 2020 (Doc. 44), Ms. Maxwell hereby respectfully submits under seal her proposed redactions to her Request to Modify Protective Order (\"Request\"), filed under seal on August 17, 2020. Ms. Maxwell also has filed her Reply under seal and contemporaneously submits her proposed redactions to that pleading.1 Ms. Maxwell has no opposition to keeping under seal, and redacting from her Request and Reply, the contents, description and discussion of the sealed materials themselves; because the government has marked them Confidential, the Protective Order requires as much. See Doc. 36, ¶ 15. The government's proposed redactions, however, go further and propose to redact have this Court redact on the premise that it would \"risk jeopardizing the government's investigation.\" 1 To the extent this Court believes this letter also should be filed publicly, counsel also has indicated her proposed redactions to this letter. DOJ-OGR-00001760",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 53 Filed 09/08/20 Page 1 of 3",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Haddon, Morgan and Foreman, P.C Jeffrey Pagliuca 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 FX 303.832.2628 www.hmflaw.com jpagliuca@hmflaw.com",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "August 24, 2020",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "VIA EMAIL The Honorable Alison J. Nathan United States District Court Southern District of New York 40 Foley Square New York, NY 10007",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Re: Proposed Redactions to Request to Modify Protective Order (Under Seal) United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Dear Judge Nathan, In accordance with this Court's Order of August 18, 2020 (Doc. 44), Ms. Maxwell hereby respectfully submits under seal her proposed redactions to her Request to Modify Protective Order (\"Request\"), filed under seal on August 17, 2020. Ms. Maxwell also has filed her Reply under seal and contemporaneously submits her proposed redactions to that pleading.1 Ms. Maxwell has no opposition to keeping under seal, and redacting from her Request and Reply, the contents, description and discussion of the sealed materials themselves; because the government has marked them Confidential, the Protective Order requires as much. See Doc. 36, ¶ 15. The government's proposed redactions, however, go further and propose to redact have this Court redact on the premise that it would \"risk jeopardizing the government's investigation.\" 1 To the extent this Court believes this letter also should be filed publicly, counsel also has indicated her proposed redactions to this letter.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00001760",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ghislaine Maxwell",
      "Jeffrey Pagliuca"
    ],
    "organizations": [
      "Haddon, Morgan and Foreman, P.C",
      "United States District Court",
      "Southern District of New York"
    ],
    "locations": [
      "Denver",
      "Colorado",
      "New York"
    ],
    "dates": [
      "August 24, 2020",
      "August 18, 2020",
      "August 17, 2020",
      "09/08/20"
    ],
    "reference_numbers": [
      "20 Cr. 330 (AJN)",
      "Doc. 44",
      "Doc. 36",
      "DOJ-OGR-00001760"
    ]
  },
  "additional_notes": "The document appears to be a formal letter from a law firm to a judge, discussing proposed redactions to a court document. The letter is typed and contains several redacted sections. The document is labeled as 'Page 1 of 3', indicating that it is part of a multi-page document."
}