{
  "document_metadata": {
    "page_number": "1",
    "document_number": "218",
    "date": "April 15, 2021",
    "document_type": "Letter",
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    "has_stamps": false
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  "full_text": "Case 1:20-cr-00330-PAE Document 218 Filed 04/19/21 Page 1 of 8\nHaddon, Morgan and Foreman, P.C\nJeffrey S. Pagliuca\n150 East 10th Avenue\nDenver, Colorado 80203\nPH 303.831.7364 FX 303.832.2628\nwww.hmtlaw.com\njpagliuca@hmtlaw.com\nApril 15, 2021\nThe Hon. Alison J. Nathan\nUnited States District Court Judge\nSouthern District of New York\n40 Foley Square\nNew York, NY 10007\nRe: Response to Government's April 5, 2021 Letter re. Ms. Maxwell's Rule 17 Subpoena\nUnited States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)\nDear Judge Nathan:\nThe government's superficial analysis of a Fed. R. Crim. P. 17 subpoena is neither accurate nor informative. The collection of various cliche phrases about Rule 17 subpoenas, selectively gathered from cases inapplicable here, is unpersuasive, and the Court should deny the requested relief because: (1) the government lacks standing to interfere with subpoenas issued to the third party respondents; and (2) this intrusion is yet another attempt to infringe on Ms. Maxwell's constitutional rights to effective assistance of counsel, a fair trial, and due process, all in violation of the 5th and 6th Amendments to the United States Constitution.\nI. Background\nIn February 2016 (and likely at least one other time in the weeks and months that followed), lawyers representing numerous civil litigants, including then-Plaintiff Virginia Giuffre, met with the government to foment an indictment of Ms. Maxwell. These lawyers and their clients sought a tactical advantage in their civil litigations, worth millions of dollars.\nThis first meeting was followed up by additional communications from these lawyers to the government. Subsequently, and unknown to Ms. Maxwell, the government brokered a deal\nDOJ-OGR-00003853",
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      "content": "Case 1:20-cr-00330-PAE Document 218 Filed 04/19/21 Page 1 of 8",
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    {
      "type": "printed",
      "content": "Haddon, Morgan and Foreman, P.C\nJeffrey S. Pagliuca\n150 East 10th Avenue\nDenver, Colorado 80203\nPH 303.831.7364 FX 303.832.2628\nwww.hmtlaw.com\njpagliuca@hmtlaw.com",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "April 15, 2021\nThe Hon. Alison J. Nathan\nUnited States District Court Judge\nSouthern District of New York\n40 Foley Square\nNew York, NY 10007",
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    {
      "type": "printed",
      "content": "Re: Response to Government's April 5, 2021 Letter re. Ms. Maxwell's Rule 17 Subpoena\nUnited States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)",
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    {
      "type": "printed",
      "content": "Dear Judge Nathan:\nThe government's superficial analysis of a Fed. R. Crim. P. 17 subpoena is neither accurate nor informative. The collection of various cliche phrases about Rule 17 subpoenas, selectively gathered from cases inapplicable here, is unpersuasive, and the Court should deny the requested relief because: (1) the government lacks standing to interfere with subpoenas issued to the third party respondents; and (2) this intrusion is yet another attempt to infringe on Ms. Maxwell's constitutional rights to effective assistance of counsel, a fair trial, and due process, all in violation of the 5th and 6th Amendments to the United States Constitution.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "I. Background\nIn February 2016 (and likely at least one other time in the weeks and months that followed), lawyers representing numerous civil litigants, including then-Plaintiff Virginia Giuffre, met with the government to foment an indictment of Ms. Maxwell. These lawyers and their clients sought a tactical advantage in their civil litigations, worth millions of dollars.\nThis first meeting was followed up by additional communications from these lawyers to the government. Subsequently, and unknown to Ms. Maxwell, the government brokered a deal",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00003853",
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  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ghislaine Maxwell",
      "Virginia Giuffre",
      "Jeffrey S. Pagliuca"
    ],
    "organizations": [
      "Haddon, Morgan and Foreman, P.C",
      "United States District Court"
    ],
    "locations": [
      "Denver, Colorado",
      "New York, NY",
      "Southern District of New York"
    ],
    "dates": [
      "April 15, 2021",
      "April 5, 2021",
      "February 2016"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 218",
      "20 Cr. 330 (AJN)",
      "DOJ-OGR-00003853"
    ]
  },
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}