{
  "document_metadata": {
    "page_number": "1",
    "document_number": "54",
    "date": "09/08/20",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
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  "full_text": "Case 1:20-cr-00330-AJN Document 54 Filed 09/08/20 Page 1 of 6\nHaddon, Morgan and Foreman, P.C\nJeffrey Pagliuca\n150 East 10th Avenue\nDenver, Colorado 80203\nPH 303.831.7364 FX 303.832.2628\nwww.hmflaw.com\njpagliuca@hmflaw.com\nAugust 24, 2020\nVIA EMAIL\nThe Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\n40 Foley Square\nNew York, NY 10007\nRe: Reply in Support of Request to Modify Protective Order (Under Seal)\nUnited States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)\nDear Judge Nathan,\nDefendant Ghislaine Maxwell filed a simple request: that she be permitted to disclose under seal (the \"Civil Litigation\") the fact that her adversary already handed over to the U.S. Attorney's Office pursuant to a subpoena.\nThe government proposes to keep in the dark about the fact and method of the disclosure. They claim the civil litigation is \"unrelated,\" that issuance of the subpoena was \"standard practice,\" and that disclosure will jeopardize an ongoing criminal investigation and \"permit dissemination of a vast swath of materials.\" Each of the government's arguments lack merit.\nThe Civil Litigation :\nFirst, the government claims the civil action is Resp. at 1. The assertion is frivolous.\n1 Ms. Maxwell has filed a letter motion which seeks leave to file this reply under seal, while providing the unredacted version to the government and the Court. This reply describes and discusses sealed materials and materials subject to the Protective Order in this case. Ms. Maxwell also simultaneously files under separate cover her proposed redactions to her Request to Modify Protective Order (Aug. 17, 2020), and this Reply, in accordance with the Court's Order of August 18, 2020 (Doc. 44).\nDOJ-OGR-00001763",
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      "content": "Case 1:20-cr-00330-AJN Document 54 Filed 09/08/20 Page 1 of 6",
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    {
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      "content": "Haddon, Morgan and Foreman, P.C\nJeffrey Pagliuca\n150 East 10th Avenue\nDenver, Colorado 80203\nPH 303.831.7364 FX 303.832.2628\nwww.hmflaw.com\njpagliuca@hmflaw.com",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "August 24, 2020\nVIA EMAIL\nThe Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\n40 Foley Square\nNew York, NY 10007",
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    },
    {
      "type": "printed",
      "content": "Re: Reply in Support of Request to Modify Protective Order (Under Seal)\nUnited States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Dear Judge Nathan,\nDefendant Ghislaine Maxwell filed a simple request: that she be permitted to disclose under seal (the \"Civil Litigation\") the fact that her adversary already handed over to the U.S. Attorney's Office pursuant to a subpoena.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The government proposes to keep in the dark about the fact and method of the disclosure. They claim the civil litigation is \"unrelated,\" that issuance of the subpoena was \"standard practice,\" and that disclosure will jeopardize an ongoing criminal investigation and \"permit dissemination of a vast swath of materials.\" Each of the government's arguments lack merit.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The Civil Litigation :\nFirst, the government claims the civil action is Resp. at 1. The assertion is frivolous.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "1 Ms. Maxwell has filed a letter motion which seeks leave to file this reply under seal, while providing the unredacted version to the government and the Court. This reply describes and discusses sealed materials and materials subject to the Protective Order in this case. Ms. Maxwell also simultaneously files under separate cover her proposed redactions to her Request to Modify Protective Order (Aug. 17, 2020), and this Reply, in accordance with the Court's Order of August 18, 2020 (Doc. 44).",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00001763",
      "position": "footer"
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  ],
  "entities": {
    "people": [
      "Jeffrey Pagliuca",
      "Alison J. Nathan",
      "Ghislaine Maxwell"
    ],
    "organizations": [
      "Haddon, Morgan and Foreman, P.C",
      "United States District Court",
      "U.S. Attorney's Office"
    ],
    "locations": [
      "Denver",
      "Colorado",
      "New York"
    ],
    "dates": [
      "August 24, 2020",
      "Aug. 17, 2020",
      "August 18, 2020",
      "09/08/20"
    ],
    "reference_numbers": [
      "20 Cr. 330 (AJN)",
      "Doc. 44",
      "DOJ-OGR-00001763"
    ]
  },
  "additional_notes": "The document appears to be a court filing with redactions. The quality is clear, but some information is obscured by black bars."
}