{
  "document_metadata": {
    "page_number": "1",
    "document_number": "41332",
    "date": "November 10, 2021",
    "document_type": "Letter",
    "has_handwriting": true,
    "has_stamps": false
  },
  "full_text": "USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC#: DATE FILED:11/11/21 BY EMAIL The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: At the November 1, 2021 pretrial conference, the Court directed the parties to file a joint letter regarding protections for witness identities at trial. In particular, the Court directed the parties to: (1) provide nomenclature for witnesses whose identities should be protected, (2) propose procedures for voir dire related to witness identities, (3) submit a proposed instruction to the jury regarding witnesses testifying under pseudonyms or under their first name only, and (4) address the logistics of offering sealed or redacted exhibits containing personal identifying information. Below are the positions of the parties regarding these logistical considerations. Because this letter contains identifying information relating to victims, the Government respectfully requests that the Court accept the Government's proposed redactions to this letter. Government position: I. Nomenclature With respect to nomenclature for witnesses whose identities should be protected at trial, the Government respectfully submits the following chart, which provides the true names of witnesses and the proposed nomenclature for those witnesses at trial. The Silvio J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 November 10, 2021 The parties are ORDERED to submit the lists referenced in this letter on or before November 14, 2021, in accordance with Dkt. No. 427. The parties may continue submitting proposed redactions in accordance with the procedures this Court has previously set. SO ORDERED. Alison J. Nathan 11/11/21 DOJ-OGR-00006353",
  "text_blocks": [
    {
      "type": "printed",
      "content": "USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC#: DATE FILED:11/11/21",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New 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:",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "At the November 1, 2021 pretrial conference, the Court directed the parties to file a joint letter regarding protections for witness identities at trial. In particular, the Court directed the parties to: (1) provide nomenclature for witnesses whose identities should be protected, (2) propose procedures for voir dire related to witness identities, (3) submit a proposed instruction to the jury regarding witnesses testifying under pseudonyms or under their first name only, and (4) address the logistics of offering sealed or redacted exhibits containing personal identifying information.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Below are the positions of the parties regarding these logistical considerations. Because this letter contains identifying information relating to victims, the Government respectfully requests that the Court accept the Government's proposed redactions to this letter.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Government position: I. Nomenclature With respect to nomenclature for witnesses whose identities should be protected at trial, the Government respectfully submits the following chart, which provides the true names of witnesses and the proposed nomenclature for those witnesses at trial.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The Silvio J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 November 10, 2021",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "The parties are ORDERED to submit the lists referenced in this letter on or before November 14, 2021, in accordance with Dkt. No. 427. The parties may continue submitting proposed redactions in accordance with the procedures this Court has previously set. SO ORDERED.",
      "position": "bottom"
    },
    {
      "type": "handwritten",
      "content": "Alison J. Nathan 11/11/21",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00006353",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ghislaine Maxwell"
    ],
    "organizations": [
      "U.S. Department of Justice",
      "United States District Court",
      "United States Courthouse"
    ],
    "locations": [
      "New York"
    ],
    "dates": [
      "November 10, 2021",
      "November 1, 2021",
      "November 14, 2021",
      "11/11/21"
    ],
    "reference_numbers": [
      "20 Cr. 330 (AJN)",
      "Dkt. No. 427",
      "DOJ-OGR-00006353"
    ]
  },
  "additional_notes": "The document appears to be a letter from the U.S. Department of Justice to Judge Alison J. Nathan regarding the case United States v. Ghislaine Maxwell. The letter discusses the protection of witness identities at trial and includes a proposed nomenclature for witnesses. The document is signed by Alison J. Nathan and includes a reference number DOJ-OGR-00006353."
}