{
  "document_metadata": {
    "page_number": "3",
    "document_number": "51",
    "date": "09/02/20",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 51 Filed 09/02/20 Page 3 of 5\n\ncase in other civil proceedings. She bases her request on the premise that disclosure of the Documents to the relevant judicial officers is allegedly necessary to ensure the fair adjudication of issues being litigated in those civil matters. But after fourteen single-spaced pages of heated rhetoric, the Defendant proffers no more than vague, speculative, and conclusory assertions as to why that is the case. She provides no coherent explanation of what argument she intends to make before those courts that requires the presentation of the materials received in discovery in this criminal matter under the existing terms of the protective order in this case. And she furnishes no substantive explanation regarding the relevance of the Documents to decisions to be made in those matters, let alone any explanation of why modifying the protective order in order to allow such disclosure is necessary to ensure the fair adjudication of those matters. In sum, the arguments the Defendant presents to the Court plainly fail to establish good cause. The Defendant's request is DENIED on this basis.\n\nIndeed, good cause for the requested modification of the protective order is further lacking because, as far as this Court can discern, the facts she is interested in conveying to the judicial decisionmakers in the Civil Cases are already publicly available, including in the Government's docketed letter on this issue. See Dkt. No. 46. In the opening paragraph of her reply letter dated August 24, 2020, the Defendant states that she is essentially seeking to disclose under seal to certain judicial officers the following factual information:\n\n1. Grand jury subpoenas were issued to an entity (“Recipient”) after the Government opened a grand jury investigation into Jeffrey Epstein and his possible co-conspirators;\n\n2. The Recipient concluded that it could not turn over materials responsive to the grand jury subpoena absent a modification of the civil protective orders in the civil cases;\n\n3",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 51 Filed 09/02/20 Page 3 of 5",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "case in other civil proceedings. She bases her request on the premise that disclosure of the Documents to the relevant judicial officers is allegedly necessary to ensure the fair adjudication of issues being litigated in those civil matters. But after fourteen single-spaced pages of heated rhetoric, the Defendant proffers no more than vague, speculative, and conclusory assertions as to why that is the case. She provides no coherent explanation of what argument she intends to make before those courts that requires the presentation of the materials received in discovery in this criminal matter under the existing terms of the protective order in this case. And she furnishes no substantive explanation regarding the relevance of the Documents to decisions to be made in those matters, let alone any explanation of why modifying the protective order in order to allow such disclosure is necessary to ensure the fair adjudication of those matters. In sum, the arguments the Defendant presents to the Court plainly fail to establish good cause. The Defendant's request is DENIED on this basis.",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "Indeed, good cause for the requested modification of the protective order is further lacking because, as far as this Court can discern, the facts she is interested in conveying to the judicial decisionmakers in the Civil Cases are already publicly available, including in the Government's docketed letter on this issue. See Dkt. No. 46. In the opening paragraph of her reply letter dated August 24, 2020, the Defendant states that she is essentially seeking to disclose under seal to certain judicial officers the following factual information:",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "1. Grand jury subpoenas were issued to an entity (“Recipient”) after the Government opened a grand jury investigation into Jeffrey Epstein and his possible co-conspirators;",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "2. The Recipient concluded that it could not turn over materials responsive to the grand jury subpoena absent a modification of the civil protective orders in the civil cases;",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "3",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00001749",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Jeffrey Epstein"
    ],
    "organizations": [],
    "locations": [],
    "dates": [
      "August 24, 2020",
      "09/02/20"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "Document 51",
      "Dkt. No. 46",
      "DOJ-OGR-00001749"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case involving the defendant and Jeffrey Epstein. The text is mostly printed, with no handwritten content or stamps visible. The document is page 3 of 5."
}