{
  "document_metadata": {
    "page_number": "1",
    "document_number": "732",
    "date": "November 22, 2021",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 732 Filed 07/14/22 Page 1 of 25\nHaddon, Morgan and Foreman, P.C\nJeffrey S. Pagliuca\n150 East 10th Avenue\nDenver, Colorado 80203\nPH 303.831.7364\nFX 303.832.2628\nwww.hmflaw.com\njpagliuca@hmflaw.com\n\nNovember 22, 2021\n\nVIA EMAIL\n\nThe Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\n40 Foley Square\nNew York, NY 10007\n\nRe: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)\n\nDear Judge Nathan,\n\nI write in response to the motions to quash Ms. Maxwell's Rule 17(c) subpoena to the Epstein Victims' Compensation Program (EVCP). Four motions to quash were filed, one each by the government, the administrator of the EVCP, Accuser-2, and Witness-3. Neither Accuser-1 nor Accuser-4 moved to quash. As explained below, the arguments against enforcement of Ms. Maxwell's subpoena lack merit, and this Court should deny the motions to quash.\n\nFACTUAL BACKGROUND\n\nOn November 15, this Court issued a Rule 17(c) subpoena to the EVCP at the request of Ms. Maxwell. The subpoena is narrow, specific, and targeted. It seeks just four categories of\n\n1 There is significant doubt whether the government has standing to move to quash, either in its own capacity or on behalf of the accusers. See United States v. Nachamie, 91 F. Supp. 2d 552, 558-61 (S.D.N.Y. 2000) (recognizing a common \"misunderstanding of the concept of standing to quash a Rule 17(c) subpoena\" and concluding the government lacked standing to move to quash in its own capacity or on behalf of the third parties). Even so, because the administrator of the EVCP and two of the accusers moved to quash, Ms. Maxwell will respond to all the arguments made in opposition to her subpoena, even the government's.\n\nDOJ-OGR-00011424",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 732 Filed 07/14/22 Page 1 of 25",
      "position": "header"
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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\nFX 303.832.2628\nwww.hmflaw.com\njpagliuca@hmflaw.com",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "November 22, 2021\n\nVIA EMAIL\n\nThe Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\n40 Foley Square\nNew York, NY 10007\n\nRe: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)\n\nDear Judge Nathan,",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "I write in response to the motions to quash Ms. Maxwell's Rule 17(c) subpoena to the Epstein Victims' Compensation Program (EVCP). Four motions to quash were filed, one each by the government, the administrator of the EVCP, Accuser-2, and Witness-3. Neither Accuser-1 nor Accuser-4 moved to quash. As explained below, the arguments against enforcement of Ms. Maxwell's subpoena lack merit, and this Court should deny the motions to quash.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "FACTUAL BACKGROUND\n\nOn November 15, this Court issued a Rule 17(c) subpoena to the EVCP at the request of Ms. Maxwell. The subpoena is narrow, specific, and targeted. It seeks just four categories of",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "1 There is significant doubt whether the government has standing to move to quash, either in its own capacity or on behalf of the accusers. See United States v. Nachamie, 91 F. Supp. 2d 552, 558-61 (S.D.N.Y. 2000) (recognizing a common \"misunderstanding of the concept of standing to quash a Rule 17(c) subpoena\" and concluding the government lacked standing to move to quash in its own capacity or on behalf of the third parties). Even so, because the administrator of the EVCP and two of the accusers moved to quash, Ms. Maxwell will respond to all the arguments made in opposition to her subpoena, even the government's.",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00011424",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Jeffrey S. Pagliuca",
      "Alison J. Nathan",
      "Ghislaine Maxwell"
    ],
    "organizations": [
      "Haddon, Morgan and Foreman, P.C",
      "United States District Court",
      "Epstein Victims' Compensation Program"
    ],
    "locations": [
      "Denver, Colorado",
      "New York"
    ],
    "dates": [
      "November 22, 2021",
      "November 15"
    ],
    "reference_numbers": [
      "Case 1:20-cr-00330-PAE",
      "Document 732",
      "20 Cr. 330 (AJN)",
      "DOJ-OGR-00011424"
    ]
  },
  "additional_notes": "The document appears to be a formal letter from a law firm to a judge, discussing a legal case involving Ghislaine Maxwell. The letter is well-formatted and includes a clear subject line and date. There are no visible redactions or damage to the document."
}