{
  "document_metadata": {
    "page_number": "1",
    "document_number": "195",
    "date": "04/05/21",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 195 Filed 04/05/21 Page 1 of 11\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\nApril 5, 2021\nBY ECF\nThe Honorable Alison J. Nathan\nUnited States District Judge\nSouthern District of New York\n40 Foley Square\nNew York, New York 10007\nRe: United States v. Ghislaine Maxwell, S2 20 Cr. 330 (AJN)\nDear Judge Nathan:\nThe Government respectfully submits this letter in connection with the Court's Order of March 24, 2021, regarding the defendant's application for an order authorizing a subpoena pursuant to Rule 17(c) of the Federal Rules of Criminal Procedure for records from Boies Schiller Flexner LLP (\"BSF\"). For the reasons set forth herein, the Government respectfully requests that the Court (1) direct the defendant to provide the Government with a copy of the proposed subpoena to BSF and notice of all existing and future applications for subpoenas under Rule 17(c) returnable in advance of trial, and (2) direct that any productions made in response to Rule 17(c) subpoenas be produced to the opposing party and marked confidential under the protective order.\nI. Background\nAs the Court is aware, the Government has produced to the defendant more than 2.7 million pages of discovery pursuant to the Government's various discovery obligations, including Rule 16. The parties are also in discussions about the timing of further productions by the Government, including material provided pursuant to 18 U.S.C. § 3500 and Giglio material.\nDOJ-OGR-00002890",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 195 Filed 04/05/21 Page 1 of 11",
      "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",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "April 5, 2021",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "BY ECF",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The Honorable Alison J. Nathan\nUnited States District Judge\nSouthern District of New York\n40 Foley Square\nNew York, New York 10007",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Re: United States v. Ghislaine Maxwell, S2 20 Cr. 330 (AJN)",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Dear Judge Nathan:",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The Government respectfully submits this letter in connection with the Court's Order of March 24, 2021, regarding the defendant's application for an order authorizing a subpoena pursuant to Rule 17(c) of the Federal Rules of Criminal Procedure for records from Boies Schiller Flexner LLP (\"BSF\"). For the reasons set forth herein, the Government respectfully requests that the Court (1) direct the defendant to provide the Government with a copy of the proposed subpoena to BSF and notice of all existing and future applications for subpoenas under Rule 17(c) returnable in advance of trial, and (2) direct that any productions made in response to Rule 17(c) subpoenas be produced to the opposing party and marked confidential under the protective order.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "I. Background",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "As the Court is aware, the Government has produced to the defendant more than 2.7 million pages of discovery pursuant to the Government's various discovery obligations, including Rule 16. The parties are also in discussions about the timing of further productions by the Government, including material provided pursuant to 18 U.S.C. § 3500 and Giglio material.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00002890",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ghislaine Maxwell"
    ],
    "organizations": [
      "U.S. Department of Justice",
      "United States Attorney",
      "Southern District of New York",
      "Boies Schiller Flexner LLP"
    ],
    "locations": [
      "New York"
    ],
    "dates": [
      "April 5, 2021",
      "March 24, 2021"
    ],
    "reference_numbers": [
      "Case 1:20-cr-00330-PAE",
      "Document 195",
      "S2 20 Cr. 330 (AJN)",
      "DOJ-OGR-00002890"
    ]
  },
  "additional_notes": "The document appears to be a formal letter from the U.S. Department of Justice to a U.S. District Judge regarding a criminal case. The document is well-formatted and free of significant damage or redactions."
}