{
  "document_metadata": {
    "page_number": "1",
    "document_number": "717",
    "date": "December 12, 2021",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 717 Filed 07/12/22 Page 1 of 10\nHaddon, Morgan and Foreman, P.C\nJeffrey S. Pagliuca\n150 East 10th Avenue\nDenver, Colorado 80203\nPH 303.831.7364\nFX 303.832.2628\nwww.hmflaw.com\njpagliuca@hmflaw.com\nDecember 12, 2021\nVIA Email\nThe Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\n40 Foley Square\nNew York, NY 10007\nRe: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)\nDear Judge Nathan,\nAs directed, I write to request that the Court permit three witnesses called by the defense to testify using pseudonyms or their first names only. Those witnesses are , Michelle Healy, and . Ms. Maxwell submits this letter at the request of these witnesses.1\nMs. Maxwell has conferred with the government about this request. The government opposes any form of protective anonymity for these witnesses.\nBACKGROUND\nSo far, there have been ten trial days in this case. During that time, several witnesses have testified using a pseudonym or their first name only. These witnesses include three of the four alleged victims (Jane, Kate, and Carolyn) and two other government witnesses (Matt and\n1 Ms. Maxwell may call as witnesses individuals who share the same true last name as the alleged victims in this case. Consistent with this Court's earlier ruling, and subject to her earlier objections, Ms. Maxwell does not oppose these witnesses testifying using pseudonyms or their first names only.\nDOJ-OGR-00011320",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 717 Filed 07/12/22 Page 1 of 10",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Haddon, Morgan and Foreman, P.C\nJeffrey S. Pagliuca\n150 East 10th Avenue\nDenver, Colorado 80203\nPH 303.831.7364\nFX 303.832.2628\nwww.hmflaw.com\njpagliuca@hmflaw.com",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "December 12, 2021\nVIA Email\nThe Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\n40 Foley Square\nNew York, NY 10007\nRe: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)\nDear Judge Nathan,",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "As directed, I write to request that the Court permit three witnesses called by the defense to testify using pseudonyms or their first names only. Those witnesses are , Michelle Healy, and . Ms. Maxwell submits this letter at the request of these witnesses.1",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Ms. Maxwell has conferred with the government about this request. The government opposes any form of protective anonymity for these witnesses.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "BACKGROUND\nSo far, there have been ten trial days in this case. During that time, several witnesses have testified using a pseudonym or their first name only. These witnesses include three of the four alleged victims (Jane, Kate, and Carolyn) and two other government witnesses (Matt and",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "1 Ms. Maxwell may call as witnesses individuals who share the same true last name as the alleged victims in this case. Consistent with this Court's earlier ruling, and subject to her earlier objections, Ms. Maxwell does not oppose these witnesses testifying using pseudonyms or their first names only.",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00011320",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Jeffrey S. Pagliuca",
      "Alison J. Nathan",
      "Ghislaine Maxwell",
      "Michelle Healy",
      "Jane",
      "Kate",
      "Carolyn",
      "Matt"
    ],
    "organizations": [
      "Haddon, Morgan and Foreman, P.C",
      "United States District Court",
      "Southern District of New York"
    ],
    "locations": [
      "Denver, Colorado",
      "New York, NY"
    ],
    "dates": [
      "December 12, 2021",
      "07/12/22"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 717",
      "20 Cr. 330 (AJN)",
      "DOJ-OGR-00011320"
    ]
  },
  "additional_notes": "The document appears to be a formal letter from a law firm to a judge, discussing a request to permit certain witnesses to testify using pseudonyms or their first names only. The letter is well-formatted and free of significant damage or redactions."
}