{
  "document_metadata": {
    "page_number": "1",
    "document_number": "324",
    "date": "August 20, 2021",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": true
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 324 Filed 08/20/21 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\nAugust 20, 2021\nVIA ECF\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 writes in response to defense counsel's letter of August 19, 2021 (Dkt. No. 323). The Court denied defense counsel's sealed, ex parte motion for an order authorizing four Rule 17(c)(3) subpoenas in a sealed opinion dated August 13, 2021, and the Court ordered defense counsel to inform the Court whether they seek any sealing or redactions. (Dkt. No. 318).\nThe defense has responded that they seek no redactions, and that they believe the burden to justify any redactions is on the Government. (Dkt. No. 323).\nBecause the Government does not have a copy of the sealed motion papers or the Court's Opinion and Order, the Government is unable to propose or justify any redactions. For instance, it appears that the motion papers include the names of victims and potential witnesses (id. at 1), which the Government would likely move to redact. The Government has conferred with defense counsel, who have informed the Government that they are unable to provide a copy of those documents absent further order of this Court. Accordingly, the Government moves for a limited\nDOJ-OGR-00005007",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 324 Filed 08/20/21 Page 1 of 2",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "U.S. Department of Justice\nUnited States Attorney\nSouthern District of New York",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "The Silvio J. Mollo Building\nOne Saint Andrew's Plaza\nNew York, New York 10007",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "August 20, 2021",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "VIA ECF",
      "position": "body"
    },
    {
      "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": "body"
    },
    {
      "type": "printed",
      "content": "Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Dear Judge Nathan:",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "The Government writes in response to defense counsel's letter of August 19, 2021 (Dkt. No. 323). The Court denied defense counsel's sealed, ex parte motion for an order authorizing four Rule 17(c)(3) subpoenas in a sealed opinion dated August 13, 2021, and the Court ordered defense counsel to inform the Court whether they seek any sealing or redactions. (Dkt. No. 318).\nThe defense has responded that they seek no redactions, and that they believe the burden to justify any redactions is on the Government. (Dkt. No. 323).\nBecause the Government does not have a copy of the sealed motion papers or the Court's Opinion and Order, the Government is unable to propose or justify any redactions. For instance, it appears that the motion papers include the names of victims and potential witnesses (id. at 1), which the Government would likely move to redact. The Government has conferred with defense counsel, who have informed the Government that they are unable to provide a copy of those documents absent further order of this Court. Accordingly, the Government moves for a limited",
      "position": "body"
    },
    {
      "type": "stamp",
      "content": "DOJ-OGR-00005007",
      "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",
      "Southern District of New York"
    ],
    "dates": [
      "August 20, 2021",
      "August 19, 2021",
      "August 13, 2021"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 324",
      "20 Cr. 330 (AJN)",
      "Dkt. No. 323",
      "Dkt. No. 318"
    ]
  },
  "additional_notes": "The document appears to be a formal letter from the U.S. Department of Justice to the Honorable Alison J. Nathan, regarding the case United States v. Ghislaine Maxwell. The document is stamped with a DOJ reference number."
}