{
  "document_metadata": {
    "page_number": "5",
    "document_number": "46",
    "date": "August 21, 2020",
    "document_type": "Court Document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 46 Filed 08/21/20 Page 5 of 5\n\nHonorable Alison J. Nathan\nAugust 21, 2020\nPage 5\n\nrequested—the defendant can make such arguments, and the Government can and will vigorously oppose them, at the appropriate stage in this case.\n\nFinally, to the extent the defendant contends that the relief requested is somehow necessary to her ability to bring issues to the attention of other courts, the Defense Letter completely fails to explain what legal argument she wishes to make in her Civil Cases based on the discovery materials she has identified or what relevance those materials have to the litigation of the Civil Cases. The fact that the Government issued grand jury subpoenas and obtained court authorization for compliance with one of those subpoenas has no conceivable relevance to disputed issues in the Civil Cases. To the extent the defendant argues that the requested relief is necessary to ensure that courts adjudicating the Civil Cases are aware of the existence of the documents at issue, the defendant identifies no specific reason why these materials are relevant to the issues pending in those cases, other than to falsely accuse the Recipient and the Government of some sort of malfeasance.6\n\nIn sum, the defendant’s arguments in favor of her application offer no explanation of the relevant legal theory the materials would support, not to mention a compelling reason for this Court to permit an end-run around the protective order and permit the use of criminal discovery to litigate a civil case. Accordingly, the application in the Defense Letter should be denied.\n\nRespectfully submitted,\n\nAUDREY STRAUSS\nActing United States Attorney\n\nBy: /s\nMaurene Comey / Alison Moe / Lara Pomerantz\nAssistant United States Attorneys\nSouthern District of New York\nTel: (212) 637-2324\n\nCc: All counsel of record, via ECF\n\n6 If anything, the Defense Letter suggests that the defendant intends to use criminal discovery materials to attack the Government in the Civil Cases, attacks of no discernable relevance in those cases and made in a forum in which the Government is not a party and would have no opportunity to respond.\n\nDOJ-OGR-00001736",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 46 Filed 08/21/20 Page 5 of 5",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Honorable Alison J. Nathan\nAugust 21, 2020\nPage 5",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "requested—the defendant can make such arguments, and the Government can and will vigorously oppose them, at the appropriate stage in this case.",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "Finally, to the extent the defendant contends that the relief requested is somehow necessary to her ability to bring issues to the attention of other courts, the Defense Letter completely fails to explain what legal argument she wishes to make in her Civil Cases based on the discovery materials she has identified or what relevance those materials have to the litigation of the Civil Cases. The fact that the Government issued grand jury subpoenas and obtained court authorization for compliance with one of those subpoenas has no conceivable relevance to disputed issues in the Civil Cases. To the extent the defendant argues that the requested relief is necessary to ensure that courts adjudicating the Civil Cases are aware of the existence of the documents at issue, the defendant identifies no specific reason why these materials are relevant to the issues pending in those cases, other than to falsely accuse the Recipient and the Government of some sort of malfeasance.6",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "In sum, the defendant’s arguments in favor of her application offer no explanation of the relevant legal theory the materials would support, not to mention a compelling reason for this Court to permit an end-run around the protective order and permit the use of criminal discovery to litigate a civil case. Accordingly, the application in the Defense Letter should be denied.",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "Respectfully submitted,\n\nAUDREY STRAUSS\nActing United States Attorney\n\nBy: /s\nMaurene Comey / Alison Moe / Lara Pomerantz\nAssistant United States Attorneys\nSouthern District of New York\nTel: (212) 637-2324",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "Cc: All counsel of record, via ECF",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "6 If anything, the Defense Letter suggests that the defendant intends to use criminal discovery materials to attack the Government in the Civil Cases, attacks of no discernable relevance in those cases and made in a forum in which the Government is not a party and would have no opportunity to respond.",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00001736",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Audrey Strauss",
      "Maurene Comey",
      "Alison Moe",
      "Lara Pomerantz"
    ],
    "organizations": [
      "United States Attorney",
      "Southern District of New York"
    ],
    "locations": [
      "New York"
    ],
    "dates": [
      "August 21, 2020"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "Document 46",
      "DOJ-OGR-00001736"
    ]
  },
  "additional_notes": "The document appears to be a court filing in a criminal case, with a formal tone and legal language. There are no visible redactions or damage to the document."
}