{
  "document_metadata": {
    "page_number": "1",
    "document_number": "32",
    "date": "July 27, 2020",
    "document_type": "Letter",
    "has_handwriting": true,
    "has_stamps": true
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 32 Filed 07/27/20 Page 1 of 1\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\nJuly 27, 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 request the opportunity to respond to defense counsel's letter motion seeking the entry of a protective order, which was filed this morning. The Government and defense counsel were in discussions - as recently as 6 p.m. last night - in the hopes of jointly proposing a protective order. Until seeing the filing on ECF this morning, the Government had understood those discussions to be ongoing. In light of the defense's letter, however, the Government respectfully requests until 5 p.m. tomorrow to submit a response.\nRespectfully submitted,\nAUDREY STRAUSS\nActing United States Attorney\nBy: /s\nAlex Rossmiller / Alison Moe / Maurene Comey\nAssistant United States Attorneys\nSouthern District of New York\nTel: (212) 637-2324\nCc: All counsel of record (by ECF)\nThe Government's response to the Defense's letter is due by 5 p.m. on July 28, 2020. The Defense may file a reply by 5 p.m. on July 29, 2020. Before the Government's response is filed, the parties must meet and confer by phone regarding this issue, and any response from the Government must contain an affirmation that the parties have done so.\nSO ORDERED.\nSO ORDERED. 7/27/20\nAlison J. Nathan, U.S.D.J.\nDOJ-OGR-00001663",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 32 Filed 07/27/20 Page 1 of 1",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "U.S. Department of Justice\nUnited States Attorney\nSouthern District of New York",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "The Silvio J. Mollo Building\nOne Saint Andrew's Plaza\nNew York, New York 10007\nJuly 27, 2020",
      "position": "header"
    },
    {
      "type": "stamp",
      "content": "USDC SDNY\nDOCUMENT\nELECTRONICALLY FILED\nDOC #:\nDATE FILED:7/27/2020",
      "position": "margin"
    },
    {
      "type": "printed",
      "content": "VIA 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": "body"
    },
    {
      "type": "printed",
      "content": "Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)\nDear Judge Nathan:",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "The Government respectfully submits this letter to request the opportunity to respond to defense counsel's letter motion seeking the entry of a protective order, which was filed this morning. The Government and defense counsel were in discussions - as recently as 6 p.m. last night - in the hopes of jointly proposing a protective order. Until seeing the filing on ECF this morning, the Government had understood those discussions to be ongoing. In light of the defense's letter, however, the Government respectfully requests until 5 p.m. tomorrow to submit a response.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Respectfully submitted,\nAUDREY STRAUSS\nActing United States Attorney",
      "position": "body"
    },
    {
      "type": "handwritten",
      "content": "/s",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "By:\nAlex Rossmiller / Alison Moe / Maurene Comey\nAssistant United States Attorneys\nSouthern District of New York\nTel: (212) 637-2324",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Cc: All counsel of record (by ECF)",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "The Government's response to the Defense's letter is due by 5 p.m. on July 28, 2020. The Defense may file a reply by 5 p.m. on July 29, 2020. Before the Government's response is filed, the parties must meet and confer by phone regarding this issue, and any response from the Government must contain an affirmation that the parties have done so.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "SO ORDERED.",
      "position": "footer"
    },
    {
      "type": "handwritten",
      "content": "SO ORDERED. 7/27/20\nAlison J. Nathan, U.S.D.J.",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00001663",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ghislaine Maxwell",
      "Alex Rossmiller",
      "Alison Moe",
      "Maurene Comey",
      "Audrey Strauss"
    ],
    "organizations": [
      "U.S. Department of Justice",
      "United States District Court",
      "Southern District of New York"
    ],
    "locations": [
      "New York"
    ],
    "dates": [
      "July 27, 2020",
      "July 28, 2020",
      "July 29, 2020"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "20 Cr. 330 (AJN)",
      "DOJ-OGR-00001663"
    ]
  },
  "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 letter is dated July 27, 2020, and is signed by Audrey Strauss, Acting United States Attorney. The document contains a stamp indicating that it was electronically filed with the USDC SDNY on July 27, 2020."
}