{
  "document_metadata": {
    "page_number": "1",
    "document_number": "244",
    "date": "April 2, 2021",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 244 Filed 04/23/21 Page 1 of 14\nHADDON\nMORGAN\nFOREMAN\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\nApril 2, 2021\nVIA ECF\nThe Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\n40 Foley Square\nNew York, NY 10007\nRe: Response to Letter Motion to Quash Rule 17 Subpoena to Boies Schiller Flexner LLP\nUnited States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)\nDear Judge Nathan,\nMs. Maxwell's Rule 17 subpoena directed to Boies Schiller Flexner LLP (\"BSF\") seeks discrete sets of material relevant to legal issues before the Court now and relevant to the jury at trial. Each item sought by the subpoena is identified with specificity and is admissible as relevant evidence in this case. The Court should therefore deny BSF's Motion to Quash (\"Motion\") (Dkt. No. 191) and direct BSF to comply with the subpoena with one narrowing modification to Request 12, the Epstein Victim's Compensation Program (\"EVCP\") Material. Ms. Maxwell agrees, based on BSF's representations, that the subpoena should be narrowed at this time in one respect. BSF proffered that they \"submitted claims and supporting evidence to the Epstein Victim's Compensation Program on behalf of several Epstein survivors who have not made separate claims against Maxwell.\" Motion at 5. BSF acknowledged that that it represents alleged victim 2 and potential trial witnesses Virginia Giuffre and Maria Farmer. Id. at 1, 5. Ms. Maxwell does not seek production of EVCP materials from any person who is not testifying as a\nDOJ-OGR-00003972",
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      "content": "Case 1:20-cr-00330-PAE Document 244 Filed 04/23/21 Page 1 of 14",
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    {
      "type": "printed",
      "content": "HADDON\nMORGAN\nFOREMAN",
      "position": "top"
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    {
      "type": "printed",
      "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",
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    {
      "type": "printed",
      "content": "April 2, 2021\nVIA ECF\nThe Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\n40 Foley Square\nNew York, NY 10007",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Re: Response to Letter Motion to Quash Rule 17 Subpoena to Boies Schiller Flexner LLP\nUnited States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Dear Judge Nathan,\nMs. Maxwell's Rule 17 subpoena directed to Boies Schiller Flexner LLP (\"BSF\") seeks discrete sets of material relevant to legal issues before the Court now and relevant to the jury at trial. Each item sought by the subpoena is identified with specificity and is admissible as relevant evidence in this case. The Court should therefore deny BSF's Motion to Quash (\"Motion\") (Dkt. No. 191) and direct BSF to comply with the subpoena with one narrowing modification to Request 12, the Epstein Victim's Compensation Program (\"EVCP\") Material. Ms. Maxwell agrees, based on BSF's representations, that the subpoena should be narrowed at this time in one respect. BSF proffered that they \"submitted claims and supporting evidence to the Epstein Victim's Compensation Program on behalf of several Epstein survivors who have not made separate claims against Maxwell.\" Motion at 5. BSF acknowledged that that it represents alleged victim 2 and potential trial witnesses Virginia Giuffre and Maria Farmer. Id. at 1, 5. Ms. Maxwell does not seek production of EVCP materials from any person who is not testifying as a",
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    {
      "type": "printed",
      "content": "DOJ-OGR-00003972",
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  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ghislaine Maxwell",
      "Jeffrey Pagliuca",
      "Virginia Giuffre",
      "Maria Farmer"
    ],
    "organizations": [
      "Haddon, Morgan and Foreman, P.C",
      "Boies Schiller Flexner LLP",
      "United States District Court",
      "Southern District of New York",
      "Epstein Victim's Compensation Program"
    ],
    "locations": [
      "Denver",
      "Colorado",
      "New York"
    ],
    "dates": [
      "April 2, 2021",
      "04/23/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 244",
      "20 Cr. 330 (AJN)",
      "Dkt. No. 191",
      "DOJ-OGR-00003972"
    ]
  },
  "additional_notes": "The document appears to be a formal letter from a law firm to a judge regarding a court case. The text is well-formatted and printed. There are no visible stamps or handwritten notes."
}