{
  "document_metadata": {
    "page_number": "1",
    "document_number": "377",
    "date": "October 27, 2021",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 377 Filed 10/27/21 Page 1 of 1 Haddon, Morgan and Foreman, P.C Jeffrey Pagliuca 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 FX 303.832.2628 www.hmflaw.com jpagliuca@hmflaw.com October 27, 2021 VIA ECF The Honorable Alison J. Nathan United States District Court Southern District of New York 40 Foley Square New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: Attached is Ms. Maxwell's motion under Federal Rule of Evidence 412. Subsection (2)(c) of the Rule requires this motion to be sealed unless this Court orders otherwise. Accordingly, unless instructed by the Court, Ms. Maxwell will not file this motion on the public docket. The Rule also requires Ms. Maxwell to notify the alleged victims whose behavior is at issue in the motion. Accordingly, unless otherwise directed, we will serve a redacted copy of this motion tailored to each alleged victim addressed in the motion on their counsel of record and provide proof of service to the Court when it is accomplished. Respectfully Submitted, Jeffrey S. Pagliuca CC: Counsel of Record (via ECF) DOJ-OGR-00005389",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 377 Filed 10/27/21 Page 1 of 1",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Haddon, Morgan and Foreman, P.C Jeffrey Pagliuca 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 FX 303.832.2628 www.hmflaw.com jpagliuca@hmflaw.com",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "October 27, 2021",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "VIA ECF The Honorable Alison J. Nathan United States District Court Southern District of New York 40 Foley Square New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: Attached is Ms. Maxwell's motion under Federal Rule of Evidence 412. Subsection (2)(c) of the Rule requires this motion to be sealed unless this Court orders otherwise. Accordingly, unless instructed by the Court, Ms. Maxwell will not file this motion on the public docket. The Rule also requires Ms. Maxwell to notify the alleged victims whose behavior is at issue in the motion. Accordingly, unless otherwise directed, we will serve a redacted copy of this motion tailored to each alleged victim addressed in the motion on their counsel of record and provide proof of service to the Court when it is accomplished. Respectfully Submitted, Jeffrey S. Pagliuca CC: Counsel of Record (via ECF)",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00005389",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ghislaine Maxwell",
      "Jeffrey S. Pagliuca",
      "Jeffrey Pagliuca"
    ],
    "organizations": [
      "Haddon, Morgan and Foreman, P.C",
      "United States District Court",
      "Southern District of New York"
    ],
    "locations": [
      "Denver",
      "Colorado",
      "New York"
    ],
    "dates": [
      "October 27, 2021"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 377",
      "20 Cr. 330 (AJN)",
      "DOJ-OGR-00005389"
    ]
  },
  "additional_notes": "The document is a letter from Jeffrey S. Pagliuca to Judge Alison J. Nathan regarding a motion under Federal Rule of Evidence 412 in the case United States v. Ghislaine Maxwell. The document is typed and appears to be in good condition."
}