{
  "document_metadata": {
    "page_number": "1",
    "document_number": "63",
    "date": "10/07/20",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": true
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 63 Filed 10/07/20 Page 1 of 8\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\nOctober 7, 2020\nVIA 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 to provide additional information in response to the Court's prior inquiry regarding the Government's plan to obtain and review other investigative files, created and maintained by other offices, which are related to the above-referenced case. In particular, at the initial conference in this matter on July 14, 2020, the Court asked the Government about its plan to ensure timely review the files of other agencies for potential disclosures in this case and highlighted the Court's expectation that the Government would be thoughtful and probing in its assessment of such a review. Consistent with the Government's commitment to take a thorough and transparent approach to its disclosure obligations, this letter outlines the relevant investigative files of which the Government is currently aware and describes the Government's approach as to each.\nI. Background Regarding the Government's Rule 16 Discovery Productions\nThe charges in this case arise out of an investigation conducted by the United States Attorney's Office for the Southern District of New York (\"USAO-SDNY\"), the Federal Bureau of Investigation (\"FBI\") New York Office, and the New York Police Department (the \"NYPD\") (collectively, the \"Prosecution Team\"). That investigation was opened in 2018 and remains ongoing. The Government has copies of the full investigative files for this case from the USAO-SDNY, the FBI New York Office, and the NYPD (the \"Prosecution Team Files\"). The bulk of the productions to date have come from the Prosecution Team Files. The Government is continuing to review the Prosecution Team Files for any additional materials that warrant disclosure.\nSpecifically, to date, the Government has produced approximately 328,863 pages of discovery to the defense in this case. Those materials include, among other things, photographs, documents seized during searches, search warrants, search warrant applications, financial records, travel records, property records, phone records, law enforcement reports, and other subpoena\nDOJ-OGR-00001787",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 63 Filed 10/07/20 Page 1 of 8",
      "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\nOctober 7, 2020",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "VIA ECF",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The 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:",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The Government respectfully submits this letter to provide additional information in response to the Court's prior inquiry regarding the Government's plan to obtain and review other investigative files, created and maintained by other offices, which are related to the above-referenced case. In particular, at the initial conference in this matter on July 14, 2020, the Court asked the Government about its plan to ensure timely review the files of other agencies for potential disclosures in this case and highlighted the Court's expectation that the Government would be thoughtful and probing in its assessment of such a review. Consistent with the Government's commitment to take a thorough and transparent approach to its disclosure obligations, this letter outlines the relevant investigative files of which the Government is currently aware and describes the Government's approach as to each.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "I. Background Regarding the Government's Rule 16 Discovery Productions",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The charges in this case arise out of an investigation conducted by the United States Attorney's Office for the Southern District of New York (\"USAO-SDNY\"), the Federal Bureau of Investigation (\"FBI\") New York Office, and the New York Police Department (the \"NYPD\") (collectively, the \"Prosecution Team\"). That investigation was opened in 2018 and remains ongoing. The Government has copies of the full investigative files for this case from the USAO-SDNY, the FBI New York Office, and the NYPD (the \"Prosecution Team Files\"). The bulk of the productions to date have come from the Prosecution Team Files. The Government is continuing to review the Prosecution Team Files for any additional materials that warrant disclosure.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Specifically, to date, the Government has produced approximately 328,863 pages of discovery to the defense in this case. Those materials include, among other things, photographs, documents seized during searches, search warrants, search warrant applications, financial records, travel records, property records, phone records, law enforcement reports, and other subpoena",
      "position": "middle"
    },
    {
      "type": "stamp",
      "content": "DOJ-OGR-00001787",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Ghislaine Maxwell",
      "Alison J. Nathan"
    ],
    "organizations": [
      "U.S. Department of Justice",
      "United States Attorney's Office for the Southern District of New York",
      "Federal Bureau of Investigation",
      "New York Police Department"
    ],
    "locations": [
      "New York",
      "Southern District of New York"
    ],
    "dates": [
      "October 7, 2020",
      "July 14, 2020",
      "2018"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "20 Cr. 330 (AJN)",
      "DOJ-OGR-00001787"
    ]
  },
  "additional_notes": "The document is a 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 stamped with a DOJ reference number."
}