{
  "document_metadata": {
    "page_number": "2",
    "document_number": "699",
    "date": "07/12/22",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 699 Filed 07/12/22 Page 2 of 3\nThe Hon. Alison J. Nathan\nMarch 9, 2021\nPage 2\nfor a criminal prosecution against them.\nIn circumstances such as these, \"it is most important 'to have a measure of accountability and for the public to have confidence in the administration of justice.'\" Lugosch, 435 F.3d at 119 (quoting United States v. Amodeo (Amodeo II), 71 F.3d 1044, 1048 (2d Cir. 1995)).\nAlthough the government claims that the items must remain sealed due to an \"ongoing investigation,\" they have failed to explain why. Beyond their ipse dixit pronouncement, the same materials they obtained via their ex parte and in camera procedure are being released to the public under the Giuffre unsealing process, without objection from the government. The name of the subpoena recipient (Boies Schiller) and the names of Chief Judge McMahon and Magistrate Judge Netburn (who issued their rulings nearly two years ago) certainly cannot alone compromise any such purported investigation. The government submission thus fails to demonstrate that denial of public access is \"essential to preserve higher values and is narrowly tailored to serve that interest.\" United States v. Aref, 533 F.3d 72, 82 (2d Cir. 2008) (quoting Press-Enterprise II, 478 U.S. at 13-14).\nMs. Maxwell believes that this Court has the jurisdiction in connection with this criminal case to determine whether to keep under seal testimony that occurred before Chief Judge McMahon that gave rise to this prosecution, especially as those documents have now become \"judicial documents\" by virtue of the pretrial motions in this case. If the Court prefers, however, Ms. Maxwell will first make application to Chief Judge McMahon to unseal those materials.\nObjections to Redactions Proposed on Pages 187-188\nMs. Maxwell also objects to the government's proposed redactions on pages 187-188. The language at issue there concerns a diary that Accuser-2 has publicly and repeatedly claimed supports her allegations. Importantly, Accuser-2 read from this allegedly corroborating diary on a NY Times podcast. Yet now the government seeks to redact her explanation for why Ms. Maxwell is not mentioned once in this diary: Accuser-2 \"stopped writing in her journal about a month after that first meeting with Epstein\" and the rest of her diary is \"personal in nature and ha[s] nothing to do with the defendant or Epstein.\"\nHow that document, or its origin, incompleteness, or lack of corroborating content could now be \"confidential\" is unexplained by the government in its request. Certainly, Accuser-2 has not acted as though the contents are \"confidential.\"\nObjections to Government's Proposed Redactions to Exhibit 5\nFor similar reasons, Ms. Maxwell objects to certain of the redactions proposed by the government to Exhibit 5 to their Response. The materials highlighted in our attached Exhibit 5 are all very public pieces of information, at the instigation of Virginia Roberts. The government has offered no explanation for their need to protect her \"privacy\" interests when she has profited with her numerous podcasts, Netflix appearances and other media participation, wherein she shares the same information. With the support of Ms. Roberts and\nDOJ-OGR-00011172",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 699 Filed 07/12/22 Page 2 of 3",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "The Hon. Alison J. Nathan\nMarch 9, 2021\nPage 2",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "for a criminal prosecution against them.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "In circumstances such as these, \"it is most important 'to have a measure of accountability and for the public to have confidence in the administration of justice.'\" Lugosch, 435 F.3d at 119 (quoting United States v. Amodeo (Amodeo II), 71 F.3d 1044, 1048 (2d Cir. 1995)).",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Although the government claims that the items must remain sealed due to an \"ongoing investigation,\" they have failed to explain why. Beyond their ipse dixit pronouncement, the same materials they obtained via their ex parte and in camera procedure are being released to the public under the Giuffre unsealing process, without objection from the government. The name of the subpoena recipient (Boies Schiller) and the names of Chief Judge McMahon and Magistrate Judge Netburn (who issued their rulings nearly two years ago) certainly cannot alone compromise any such purported investigation. The government submission thus fails to demonstrate that denial of public access is \"essential to preserve higher values and is narrowly tailored to serve that interest.\" United States v. Aref, 533 F.3d 72, 82 (2d Cir. 2008) (quoting Press-Enterprise II, 478 U.S. at 13-14).",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Ms. Maxwell believes that this Court has the jurisdiction in connection with this criminal case to determine whether to keep under seal testimony that occurred before Chief Judge McMahon that gave rise to this prosecution, especially as those documents have now become \"judicial documents\" by virtue of the pretrial motions in this case. If the Court prefers, however, Ms. Maxwell will first make application to Chief Judge McMahon to unseal those materials.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Objections to Redactions Proposed on Pages 187-188",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Ms. Maxwell also objects to the government's proposed redactions on pages 187-188. The language at issue there concerns a diary that Accuser-2 has publicly and repeatedly claimed supports her allegations. Importantly, Accuser-2 read from this allegedly corroborating diary on a NY Times podcast. Yet now the government seeks to redact her explanation for why Ms. Maxwell is not mentioned once in this diary: Accuser-2 \"stopped writing in her journal about a month after that first meeting with Epstein\" and the rest of her diary is \"personal in nature and ha[s] nothing to do with the defendant or Epstein.\"",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "How that document, or its origin, incompleteness, or lack of corroborating content could now be \"confidential\" is unexplained by the government in its request. Certainly, Accuser-2 has not acted as though the contents are \"confidential.\"",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Objections to Government's Proposed Redactions to Exhibit 5",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "For similar reasons, Ms. Maxwell objects to certain of the redactions proposed by the government to Exhibit 5 to their Response. The materials highlighted in our attached Exhibit 5 are all very public pieces of information, at the instigation of Virginia Roberts. The government has offered no explanation for their need to protect her \"privacy\" interests when she has profited with her numerous podcasts, Netflix appearances and other media participation, wherein she shares the same information. With the support of Ms. Roberts and",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00011172",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ms. Maxwell",
      "Chief Judge McMahon",
      "Magistrate Judge Netburn",
      "Accuser-2",
      "Epstein",
      "Virginia Roberts"
    ],
    "organizations": [
      "Boies Schiller",
      "NY Times",
      "Netflix",
      "DOJ"
    ],
    "locations": [],
    "dates": [
      "March 9, 2021",
      "07/12/22"
    ],
    "reference_numbers": [
      "Case 1:20-cr-00330-PAE",
      "Document 699",
      "DOJ-OGR-00011172"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case involving Ms. Maxwell. The text is printed and there are no visible stamps or handwritten notes. The document is page 2 of a 3-page document."
}