{
  "document_metadata": {
    "page_number": "14 of 22",
    "document_number": "140",
    "date": "02/04/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
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  "full_text": "Case 1:20-cr-00330-AJN Document 140 Filed 02/04/21 Page 14 of 22\n\nNeither Miller nor Smith supports a conclusion that Maxwell had anything but a legitimate and reasonable expectation of privacy in her . First, Maxwell did not “voluntarily convey”  sued her, not the other way around. Moreover, Maxwell declined to answer . None of this was voluntary.\n\nSecond, Maxwell’s expectation of privacy in her  is not limited in the way Miller’s expectation of privacy was limited in his bank records. To the contrary, both Maxwell’s  were confidential under the Protective Order. And while the Protective Order did not apply to evidence produced at trial, the case settled before trial, thereby confirming Maxwell’s legitimate expectation that the  would not be shared outside the attorneys working in the case and, if necessary, the district court.\n\nThird, Maxwell reasonably understood that the  would not be shared with the government. Giuffre proposed a law enforcement exception to the Protective Order’s confidentiality requirement, but Maxwell rejected the exception and the district court never adopted it. Unlike in Smith and Miller, Maxwell did not “assume the risk” that her  would be divulged to the government.\n\nHad the government obtained the  from Maxwell’s attorneys, there would be no question that the government’s conduct would constitute a Fourth Amendment search. “[C]lients of an attorney maintain a legitimate expectation of privacy in their client files.” DeMassa v. Nunez, 770 F.2d 1505, 1506 (9th Cir. 1985); see Doe v. Broderick, 225 F.3d 440, 450–52 (4th Cir. 2000) (holding that detective’s examination of a patient file held by a methadone clinic was a search and, without probable cause, violated the patient’s Fourth\n\n10\n\nDOJ-OGR-00002562",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 140 Filed 02/04/21 Page 14 of 22",
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      "type": "printed",
      "content": "Neither Miller nor Smith supports a conclusion that Maxwell had anything but a legitimate and reasonable expectation of privacy in her . First, Maxwell did not “voluntarily convey”  sued her, not the other way around. Moreover, Maxwell declined to answer . None of this was voluntary.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Second, Maxwell’s expectation of privacy in her  is not limited in the way Miller’s expectation of privacy was limited in his bank records. To the contrary, both Maxwell’s  were confidential under the Protective Order. And while the Protective Order did not apply to evidence produced at trial, the case settled before trial, thereby confirming Maxwell’s legitimate expectation that the  would not be shared outside the attorneys working in the case and, if necessary, the district court.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Third, Maxwell reasonably understood that the  would not be shared with the government. Giuffre proposed a law enforcement exception to the Protective Order’s confidentiality requirement, but Maxwell rejected the exception and the district court never adopted it. Unlike in Smith and Miller, Maxwell did not “assume the risk” that her  would be divulged to the government.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Had the government obtained the  from Maxwell’s attorneys, there would be no question that the government’s conduct would constitute a Fourth Amendment search. “[C]lients of an attorney maintain a legitimate expectation of privacy in their client files.” DeMassa v. Nunez, 770 F.2d 1505, 1506 (9th Cir. 1985); see Doe v. Broderick, 225 F.3d 440, 450–52 (4th Cir. 2000) (holding that detective’s examination of a patient file held by a methadone clinic was a search and, without probable cause, violated the patient’s Fourth",
      "position": "middle"
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    {
      "type": "printed",
      "content": "10",
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    {
      "type": "printed",
      "content": "DOJ-OGR-00002562",
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  ],
  "entities": {
    "people": [
      "Miller",
      "Smith",
      "Maxwell",
      "Giuffre"
    ],
    "organizations": [],
    "locations": [],
    "dates": [
      "02/04/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "Document 140",
      "DOJ-OGR-00002562"
    ]
  },
  "additional_notes": "The document appears to be a court filing with redactions. The text is mostly intact, but some sections are blacked out."
}