{
  "document_metadata": {
    "page_number": "1",
    "document_number": "162",
    "date": "02/26/21",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 162 Filed 02/26/21 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\nFebruary 26, 2021\nBY ECF & ELECTRONIC MAIL\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 under seal the enclosed unredacted version of its memorandum of law and accompanying exhibits in opposition to the defendant's twelve pre-trial motions. Additionally, the Government respectfully submits proposed redactions to its memorandum of law and three exhibits, Exhibits 1, 5, and 7. Consistent with the redactions contained in the defendant's motions, the Government's proposed redactions are narrowly tailored to (1) cover information implicating the privacy interests of third parties, (2) cover Confidential Material produced by the Government in discovery and governed by paragraph 15 of the Protective Order in this case (Dkt. 36), (3) cover information submitted under seal to other judicial officers or information another judicial officer has determined should remain under seal, and (4) protect the integrity of the Government's ongoing investigation.\nIn addition, the Government respectfully requests that certain exhibits be filed entirely under seal. In particular, the Government respectfully submits that (1) Exhibits 8 and 9, filings submitted under seal to other judicial officers, should similarly be filed under seal in this case while the Government's grand jury investigation remains ongoing; and (2) Exhibit 11 should be filed under seal because it contains information which another judicial officer has determined should remain under seal.\nDOJ-OGR-00002742",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 162 Filed 02/26/21 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": "February 26, 2021",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "BY ECF & ELECTRONIC MAIL",
      "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": "middle"
    },
    {
      "type": "printed",
      "content": "Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Dear Judge Nathan:",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The Government respectfully submits under seal the enclosed unredacted version of its memorandum of law and accompanying exhibits in opposition to the defendant's twelve pre-trial motions. Additionally, the Government respectfully submits proposed redactions to its memorandum of law and three exhibits, Exhibits 1, 5, and 7. Consistent with the redactions contained in the defendant's motions, the Government's proposed redactions are narrowly tailored to (1) cover information implicating the privacy interests of third parties, (2) cover Confidential Material produced by the Government in discovery and governed by paragraph 15 of the Protective Order in this case (Dkt. 36), (3) cover information submitted under seal to other judicial officers or information another judicial officer has determined should remain under seal, and (4) protect the integrity of the Government's ongoing investigation.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "In addition, the Government respectfully requests that certain exhibits be filed entirely under seal. In particular, the Government respectfully submits that (1) Exhibits 8 and 9, filings submitted under seal to other judicial officers, should similarly be filed under seal in this case while the Government's grand jury investigation remains ongoing; and (2) Exhibit 11 should be filed under seal because it contains information which another judicial officer has determined should remain under seal.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00002742",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ghislaine Maxwell"
    ],
    "organizations": [
      "U.S Department of Justice",
      "United States Attorney",
      "United States District Court"
    ],
    "locations": [
      "New York"
    ],
    "dates": [
      "February 26, 2021"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "Document 162",
      "20 Cr. 330 (AJN)",
      "Dkt. 36",
      "DOJ-OGR-00002742"
    ]
  },
  "additional_notes": "The document appears to be a formal 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 submission of certain documents under seal and proposed redactions."
}