{
  "document_metadata": {
    "page_number": "2",
    "document_number": "2:20-cv-00839-JES-MRM",
    "date": null,
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 2:20-cv-00839-JES-MRM Document 122-2 Filed 04/16/21 Page 2 of 8 App.-0134 has attempted to join. Ms. Villafana's response was that she was unaware of any such investigation. Plaintiff also seems to be claiming that she is part of this alleged investigation and, as a consequence, has inappropriately attempted to claim a non-existent \"investigative privilege\" which has been replaced by her equally inappropriate \"public interest privilege.\" Issues related to Plaintiff's ongoing failures to produce discovery, including her specious claims of privilege have been raised and fully briefed. Ms. Maxwell incorporates her Motion to Compel Responses to Defendant's First Set of Discovery Requests (Doc. # 75) and Reply in support thereof (Doc. # 92), by reference. According to Plaintiff, Ms. Maxwell \"cannot show any significant reason for needing\" the information. This is, again, a meritless argument which ignores the fact that Ms. Maxwell is entitled to the information under the rules of discovery. And, the \"need\" for the information is both obvious and necessary for at least three reasons: first, any communications between Plaintiff, her lawyers and law enforcement are likely inconsistent with statements Plaintiff has made to the media; second, the statements will reflect Plaintiff's motive and bias in bringing this litigation; and third, knowing the information will allow Ms. Maxwell to access the impact on any 5th Amendment privilege. Plaintiff, at this point, should be either required to provide the information or accept a stay in the proceedings as a consequence of her failure to comply with her discovery obligations. She should not be allowed to brandish this, likely nonexistent, sword but deny Ms. Maxwell the opportunity to adequately prepare for her deposition and other discovery matters. Accordingly, in the event that the Plaintiff continues to fail to reveal the information that she claims to have regarding some \"ongoing criminal investigation,\" Ms. Maxwell moves to stay these proceedings. 2 DOJ-OGR-00003798",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 2:20-cv-00839-JES-MRM Document 122-2 Filed 04/16/21 Page 2 of 8 App.-0134",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "has attempted to join. Ms. Villafana's response was that she was unaware of any such investigation. Plaintiff also seems to be claiming that she is part of this alleged investigation and, as a consequence, has inappropriately attempted to claim a non-existent \"investigative privilege\" which has been replaced by her equally inappropriate \"public interest privilege.\" Issues related to Plaintiff's ongoing failures to produce discovery, including her specious claims of privilege have been raised and fully briefed. Ms. Maxwell incorporates her Motion to Compel Responses to Defendant's First Set of Discovery Requests (Doc. # 75) and Reply in support thereof (Doc. # 92), by reference. According to Plaintiff, Ms. Maxwell \"cannot show any significant reason for needing\" the information. This is, again, a meritless argument which ignores the fact that Ms. Maxwell is entitled to the information under the rules of discovery. And, the \"need\" for the information is both obvious and necessary for at least three reasons: first, any communications between Plaintiff, her lawyers and law enforcement are likely inconsistent with statements Plaintiff has made to the media; second, the statements will reflect Plaintiff's motive and bias in bringing this litigation; and third, knowing the information will allow Ms. Maxwell to access the impact on any 5th Amendment privilege. Plaintiff, at this point, should be either required to provide the information or accept a stay in the proceedings as a consequence of her failure to comply with her discovery obligations. She should not be allowed to brandish this, likely nonexistent, sword but deny Ms. Maxwell the opportunity to adequately prepare for her deposition and other discovery matters. Accordingly, in the event that the Plaintiff continues to fail to reveal the information that she claims to have regarding some \"ongoing criminal investigation,\" Ms. Maxwell moves to stay these proceedings.",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "2",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00003798",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Ms. Villafana",
      "Plaintiff",
      "Ms. Maxwell"
    ],
    "organizations": [],
    "locations": [],
    "dates": [
      "04/16/21"
    ],
    "reference_numbers": [
      "2:20-cv-00839-JES-MRM",
      "Doc. # 75",
      "Doc. # 92",
      "DOJ-OGR-00003798"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a legal case, with a formal tone and legal language. There are no visible redactions or damage to the document."
}