{
  "document_metadata": {
    "page_number": "11",
    "document_number": "134",
    "date": "02/04/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 134 Filed 02/04/21 Page 11 of 23\n\nC. The Settlement And Boies Schiller's Refusal To Comply With The Protective Order\n\nIn 2017, the parties settled the defamation claim, and the case was dismissed. Giuffre v. Maxwell, 325 F. Supp. 3d 428, 436 (S.D.N.Y. 2018), vacated and remanded sub nom. Brown, 929 F.3d 41. As the district court found, \"a significant, if not determinative, factor\" in reaching a settlement was its confidentiality. Id. at 446.\n\nAfter the case was settled and concluded, Maxwell repeatedly invoked Paragraph 12 of the Protective Order and demanded that Giuffre either return or destroy all confidential information, including her deposition transcripts. Boies Schiller refused. [REDACTED].\n\nD. The Government's False Statements To [REDACTED]\n\nOnly in August 2020, after she was indicted in this case, did Maxwell finally learn that the government had obtained the [REDACTED] file by grand jury subpoena. Maxwell also learned that, to overcome the strictures of the Protective Order, the government had instituted an ex parte proceeding before [REDACTED] (S.D.N.Y). [REDACTED].\n\nNeedless to say, neither Maxwell nor her attorneys were given the opportunity to oppose that application or to contest the government's representations in support of the application. This was all in direct violation of Paragraph 14 of the Protective Order, which provides that the order may be modified by the court only \"for good cause shown following notice to all parties and an opportunity to be heard.\" Ex. A ¶ 14 (emphasis added).\n\nIn its ex parte application, the prosecutors professed that they had sought out [REDACTED]\n\n6\nDOJ-OGR-00002358",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 134 Filed 02/04/21 Page 11 of 23",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "C. The Settlement And Boies Schiller's Refusal To Comply With The Protective Order",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "In 2017, the parties settled the defamation claim, and the case was dismissed. Giuffre v. Maxwell, 325 F. Supp. 3d 428, 436 (S.D.N.Y. 2018), vacated and remanded sub nom. Brown, 929 F.3d 41. As the district court found, \"a significant, if not determinative, factor\" in reaching a settlement was its confidentiality. Id. at 446.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "After the case was settled and concluded, Maxwell repeatedly invoked Paragraph 12 of the Protective Order and demanded that Giuffre either return or destroy all confidential information, including her deposition transcripts. Boies Schiller refused. [REDACTED].",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "D. The Government's False Statements To [REDACTED]",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Only in August 2020, after she was indicted in this case, did Maxwell finally learn that the government had obtained the [REDACTED] file by grand jury subpoena. Maxwell also learned that, to overcome the strictures of the Protective Order, the government had instituted an ex parte proceeding before [REDACTED] (S.D.N.Y). [REDACTED].",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Needless to say, neither Maxwell nor her attorneys were given the opportunity to oppose that application or to contest the government's representations in support of the application. This was all in direct violation of Paragraph 14 of the Protective Order, which provides that the order may be modified by the court only \"for good cause shown following notice to all parties and an opportunity to be heard.\" Ex. A ¶ 14 (emphasis added).",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "In its ex parte application, the prosecutors professed that they had sought out [REDACTED]",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "6",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00002358",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Maxwell",
      "Giuffre",
      "Brown"
    ],
    "organizations": [
      "Boies Schiller"
    ],
    "locations": [
      "S.D.N.Y."
    ],
    "dates": [
      "2017",
      "2018",
      "2020",
      "02/04/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "Document 134",
      "325 F. Supp. 3d 428",
      "929 F.3d 41",
      "Ex. A ¶ 14",
      "DOJ-OGR-00002358"
    ]
  },
  "additional_notes": "The document appears to be a court filing with redactions. The redactions are likely due to sensitive information being withheld."
}