{
  "document_metadata": {
    "page_number": "1",
    "document_number": "715",
    "date": "07/12/22",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 715 Filed 07/12/22 Page 1 of 8\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\nDecember 6, 2021\nVIA Email\nThe Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\n40 Foley Square\nNew York, NY 10007\nRe: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)\nDear Judge Nathan,\nI write in response to the government's untimely disclosure of expert opinion testimony to be offered by Computer Forensic Examiner Stephen Flatley of the Federal Bureau of Investigation's Computer Analysis Response Team. As explained below, this Court should preclude Examiner Flatley from offering the newly-disclosed expert opinion testimony—everything newly disclosed in the November 26 disclosure, the December 3 email, or the December 5 email.\nBACKGROUND\nOn September 15, the government wrote to Ms. Maxwell's counsel to describe the testimony it expected to elicit from Examiner Flatley. The government insisted Examiner Flatley would not offer expert opinions. Instead, the government claimed Examiner Flatley would offer fact testimony about the steps he took to extract and clone certain devices seized under a search warrant. This was the full description of the expected testimony:\nThe Government anticipates that, if called as a witness, Examiner Flatley will testify about his extraction of devices seized pursuant to court-authorized search warrant.\nDOJ-OGR-00011311",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 715 Filed 07/12/22 Page 1 of 8",
      "position": "header"
    },
    {
      "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": "December 6, 2021\nVIA Email\nThe Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\n40 Foley Square\nNew York, NY 10007\nRe: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)\nDear Judge Nathan,",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "I write in response to the government's untimely disclosure of expert opinion testimony to be offered by Computer Forensic Examiner Stephen Flatley of the Federal Bureau of Investigation's Computer Analysis Response Team. As explained below, this Court should preclude Examiner Flatley from offering the newly-disclosed expert opinion testimony—everything newly disclosed in the November 26 disclosure, the December 3 email, or the December 5 email.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "BACKGROUND\nOn September 15, the government wrote to Ms. Maxwell's counsel to describe the testimony it expected to elicit from Examiner Flatley. The government insisted Examiner Flatley would not offer expert opinions. Instead, the government claimed Examiner Flatley would offer fact testimony about the steps he took to extract and clone certain devices seized under a search warrant. This was the full description of the expected testimony:\nThe Government anticipates that, if called as a witness, Examiner Flatley will testify about his extraction of devices seized pursuant to court-authorized search warrant.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00011311",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Jeffrey S. Pagliuca",
      "Alison J. Nathan",
      "Ghislaine Maxwell",
      "Stephen Flatley"
    ],
    "organizations": [
      "Haddon, Morgan and Foreman, P.C",
      "United States District Court",
      "Federal Bureau of Investigation"
    ],
    "locations": [
      "Denver",
      "Colorado",
      "New York"
    ],
    "dates": [
      "December 6, 2021",
      "September 15",
      "November 26",
      "December 3",
      "December 5",
      "07/12/22"
    ],
    "reference_numbers": [
      "20 Cr. 330 (AJN)",
      "DOJ-OGR-00011311",
      "1:20-cr-00330-PAE",
      "715"
    ]
  },
  "additional_notes": "The document appears to be a formal letter from a law firm to a judge, discussing a court case involving Ghislaine Maxwell. The letter is typed and has a professional tone. There are no visible redactions or damage to the document."
}