{
  "document_metadata": {
    "page_number": "3 of 3",
    "document_number": "699",
    "date": "07/12/22",
    "document_type": "Court Document",
    "has_handwriting": true,
    "has_stamps": false
  },
  "full_text": "Page 3 of 3 Document 699 Filed 07/12/22 Case 1:20-cr-00330-PAE The Hon. Alison J. Nathan March 9, 2021 Page 3 her counsel, her entire draft \"memoir\" (entitled \"The Billionaire Boys Club\") was released by the Second Circuit in Brown v. Maxwell. See Case No. 18-2868 (2d Cir.), Dkt. 278 at 564 et seq. Because Ms. Robertsons has already publicly proclaimed the same allegations as are represented in the Kramer notes at 4-5, attached as Exhibit 5 to the government's Response, the government cannot show any privacy interest in keeping those portions redacted or sealed. Objections to Government's Failure to Redact Materials Under Seal Pages 129-134 The government proposes, at pages 129-134, to redact only certain portions of Ms. Maxwell's sealed deposition testimony. In Ms. Maxwell's case, Judge Preska has ruled that certain questions and answers are still under seal and subject to the Protective Order in the Giuffre v. Ghislaine Maxwell, Case No. 15-cv-7433-LAP, Dkt. 1212-1. The Motions, we limited our proposed redactions to publicize those sealed portions which reflect Judge Preska's rulings are contained in the attached exhibit. For the foregoing reasons, Ms. Maxwell respectfully requests the Court publicly docket the Response, with the following exceptions: Accept Ms. Maxwell's proposed redactions to pages 129-1341 Accept the government's proposed redactions to pages 158-186; Accept Ms. Maxwell's proposed redactions to pages 187-188;2 Accept Ms. Maxwell's proposed redactions to Exhibit 5.3 Respectfully submitted Laura A. Menninger Counsel of Record CC: Counsel of Record 1 Ms. Maxwell has indicated additional lines that ought to be redacted with yellow highlighting. 2 Ms. Maxwell disagrees with all of the government's redactions on these pages, as indicated by the red boxes. 3 The blue boxes on the attached Exhibit 5 indicate the government redactions opposed by Ms. Maxwell. Ms. Maxwell does not oppose the other redacted boxes proposed by the government to protect the privacy interests of other non-parties. DOJ-OGR-00011173",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Page 3 of 3 Document 699 Filed 07/12/22",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE The Hon. Alison J. Nathan March 9, 2021 Page 3",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "her counsel, her entire draft \"memoir\" (entitled \"The Billionaire Boys Club\") was released by the Second Circuit in Brown v. Maxwell. See Case No. 18-2868 (2d Cir.), Dkt. 278 at 564 et seq. Because Ms. Robertsons has already publicly proclaimed the same allegations as are represented in the Kramer notes at 4-5, attached as Exhibit 5 to the government's Response, the government cannot show any privacy interest in keeping those portions redacted or sealed.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Objections to Government's Failure to Redact Materials Under Seal Pages 129-134 The government proposes, at pages 129-134, to redact only certain portions of Ms. Maxwell's sealed deposition testimony. In Ms. Maxwell's case, Judge Preska has ruled that certain questions and answers are still under seal and subject to the Protective Order in the Giuffre v. Ghislaine Maxwell, Case No. 15-cv-7433-LAP, Dkt. 1212-1. The Motions, we limited our proposed redactions to publicize those sealed portions which reflect Judge Preska's rulings are contained in the attached exhibit.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "For the foregoing reasons, Ms. Maxwell respectfully requests the Court publicly docket the Response, with the following exceptions: Accept Ms. Maxwell's proposed redactions to pages 129-1341 Accept the government's proposed redactions to pages 158-186; Accept Ms. Maxwell's proposed redactions to pages 187-188;2 Accept Ms. Maxwell's proposed redactions to Exhibit 5.3",
      "position": "body"
    },
    {
      "type": "handwritten",
      "content": "Laura A. Menninger",
      "position": "signature"
    },
    {
      "type": "printed",
      "content": "Respectfully submitted Laura A. Menninger Counsel of Record CC: Counsel of Record",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "1 Ms. Maxwell has indicated additional lines that ought to be redacted with yellow highlighting. 2 Ms. Maxwell disagrees with all of the government's redactions on these pages, as indicated by the red boxes. 3 The blue boxes on the attached Exhibit 5 indicate the government redactions opposed by Ms. Maxwell. Ms. Maxwell does not oppose the other redacted boxes proposed by the government to protect the privacy interests of other non-parties.",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00011173",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ms. Robertsons",
      "Ms. Maxwell",
      "Ghislaine Maxwell",
      "Laura A. Menninger"
    ],
    "organizations": [
      "Second Circuit"
    ],
    "locations": [],
    "dates": [
      "March 9, 2021",
      "07/12/22"
    ],
    "reference_numbers": [
      "Case No. 18-2868",
      "Case No. 15-cv-7433-LAP",
      "Dkt. 278",
      "Dkt. 1212-1",
      "DOJ-OGR-00011173"
    ]
  },
  "additional_notes": "The document appears to be a court filing with a mix of printed and handwritten text. The handwritten text is a signature. The document contains references to court cases and exhibits."
}