{
  "document_metadata": {
    "page_number": "1 of 2",
    "document_number": "598",
    "date": "02/11/22",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 598 Filed 02/11/22 Page 1 of 2\nU.S. Department of Justice\nUnited States Attorney\nSouthern District of New York\nThe Silvio J. Mollo Building\nOne Saint Andrew's Plaza\nNew York, New York 10007\nFebruary 11, 2022\nBY ECF\nThe Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\nUnited States Courthouse\n40 Foley Square\nNew York, New York 10007\nRe: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)\nDear Judge Nathan:\nThe Government respectfully submits this letter in response to the Court's January 26, 2022 Order (Dkt. No. 585), which directed the Government to respond to the New York Times Company's motion to unseal the completed questionnaires for the twelve seated jurors in this case (Dkt. No. 583). The Government agrees with the New York Times Company that the questionnaires for the twelve seated jurors should be made public, with limited redactions to protect juror privacy. Under the circumstances presented here, where jury selection and the trial have been completed, releasing juror questionnaires is consistent with the strong presumption of access to the jury selection process, including juror questionnaires. See United States v. King, 140 F.3d 76, 80 (2d Cir. 1998); United States v. Avenatti, No. 19 Cr. 373 (PGG), 2021 WL 2809919, at *48 (S.D.N.Y. July 6, 2021).\nRegarding redactions, the Government proposes limited redactions to only one juror questionnaire and will submit the proposed redactions by email to Chambers. The redactions are limited to sensitive personal information, which the juror discussed at a sealed sidebar during voir dire. Aside from the limited redactions on one juror's questionnaire, the Government otherwise\nDOJ-OGR-00008921",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 598 Filed 02/11/22 Page 1 of 2",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "U.S. Department of Justice\nUnited States Attorney\nSouthern District of New York\nThe Silvio J. Mollo Building\nOne Saint Andrew's Plaza\nNew York, New York 10007",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "February 11, 2022",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "BY ECF\nThe Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\nUnited States Courthouse\n40 Foley Square\nNew York, New York 10007",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Dear Judge Nathan:\nThe Government respectfully submits this letter in response to the Court's January 26, 2022 Order (Dkt. No. 585), which directed the Government to respond to the New York Times Company's motion to unseal the completed questionnaires for the twelve seated jurors in this case (Dkt. No. 583). The Government agrees with the New York Times Company that the questionnaires for the twelve seated jurors should be made public, with limited redactions to protect juror privacy. Under the circumstances presented here, where jury selection and the trial have been completed, releasing juror questionnaires is consistent with the strong presumption of access to the jury selection process, including juror questionnaires. See United States v. King, 140 F.3d 76, 80 (2d Cir. 1998); United States v. Avenatti, No. 19 Cr. 373 (PGG), 2021 WL 2809919, at *48 (S.D.N.Y. July 6, 2021).\nRegarding redactions, the Government proposes limited redactions to only one juror questionnaire and will submit the proposed redactions by email to Chambers. The redactions are limited to sensitive personal information, which the juror discussed at a sealed sidebar during voir dire. Aside from the limited redactions on one juror's questionnaire, the Government otherwise",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00008921",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ghislaine Maxwell"
    ],
    "organizations": [
      "U.S. Department of Justice",
      "United States Attorney",
      "New York Times Company"
    ],
    "locations": [
      "New York",
      "Southern District of New York"
    ],
    "dates": [
      "February 11, 2022",
      "January 26, 2022",
      "July 6, 2021"
    ],
    "reference_numbers": [
      "Case 1:20-cr-00330-PAE",
      "Document 598",
      "20 Cr. 330 (AJN)",
      "Dkt. No. 585",
      "Dkt. No. 583",
      "19 Cr. 373 (PGG)",
      "DOJ-OGR-00008921"
    ]
  },
  "additional_notes": "The document appears to be a formal letter from the U.S. Department of Justice to the Honorable Alison J. Nathan regarding the case United States v. Ghislaine Maxwell. The document is well-formatted and free of significant damage or redactions, except for the presence of a reference number 'DOJ-OGR-00008921' at the bottom, which might indicate some level of internal tracking or classification."
}