{
  "document_metadata": {
    "page_number": "1 of 2",
    "document_number": "410",
    "date": "11/04/21",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 410 Filed 11/04/21 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\nNovember 3, 2021\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:\nAttached please find the parties' joint request to charge and proposed verdict sheet. The Government is docketing a redacted version today and submitting the unredacted versions to the Court. The redline text in the documents reflect the objections of the defense. Further detail of the parties' objections are contained in comment bubbles.\nThe Government has proposed the only redactions in the Request to Charge. These proposed redactions are consistent with the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Although the Government's request to charge is a judicial document subject to the common law presumption of access, the proposed redactions are narrowly tailored to protect the privacy interests of a third party.\nThe Government is also providing under seal Exhibit A, which pertains to a defense comment. The defense informs the Government that this exhibit is a document from another case\nDOJ-OGR-00006065",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 410 Filed 11/04/21 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": "November 3, 2021",
      "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": "middle"
    },
    {
      "type": "printed",
      "content": "Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)\nDear Judge Nathan:",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Attached please find the parties' joint request to charge and proposed verdict sheet. The Government is docketing a redacted version today and submitting the unredacted versions to the Court. The redline text in the documents reflect the objections of the defense. Further detail of the parties' objections are contained in comment bubbles.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The Government has proposed the only redactions in the Request to Charge. These proposed redactions are consistent with the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Although the Government's request to charge is a judicial document subject to the common law presumption of access, the proposed redactions are narrowly tailored to protect the privacy interests of a third party.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The Government is also providing under seal Exhibit A, which pertains to a defense comment. The defense informs the Government that this exhibit is a document from another case",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00006065",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ghislaine Maxwell"
    ],
    "organizations": [
      "U.S Department of Justice",
      "United States Attorney",
      "United States District Court",
      "Southern District of New York"
    ],
    "locations": [
      "New York"
    ],
    "dates": [
      "November 3, 2021",
      "11/04/21"
    ],
    "reference_numbers": [
      "20 Cr. 330 (AJN)",
      "410",
      "DOJ-OGR-00006065"
    ]
  },
  "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 letter discusses the joint request to charge and proposed verdict sheet, and mentions redactions and sealed exhibits."
}