{
  "document_metadata": {
    "page_number": "1",
    "document_number": "35",
    "date": "07/29/20",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 35 Filed 07/29/20 Page 1 of 5\nCOHEN & GRESSER LLP\n800 Third Avenue\nNew York, NY 10022\n+1 212 957 7600 phone\nwww.cohengresser.com\nMark S. Cohen\n+1 (212) 957-7600\nmcohen@cohengresser.com\nChristian R. Everdell\n+1 (212) 957-7600\nceverdell@cohengresser.com\nJuly 29, 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:\nOn behalf of our client, Ghislaine Maxwell, we respectfully submit this letter to reply to the government's response letter and submission regarding the proposed protective order in the above-captioned case, dated July 28, 2020 (\"Government's Response\" or \"Gov't Resp.\") (Dkt. 33).\nThe parties have met and conferred, resolving nearly all the issues relating to the proposed protective order. The parties agree that there are two areas of dispute as to which we require guidance from the Court. As noted in our opening letter and below, we respectfully submit that the arguments made by the government are unavailing, and that the defense's proposed protective order, attached as Exhibit A to our initial submission (Dkt. 29), should be entered by the Court.\n1. Referencing Individuals Who Have Publicly Identified Themselves\nThe starting point for evaluating the scope of a proposed protective order is whether there are valid privacy interests at issue. It is the government's burden to establish \"good cause\" that disclosure will cause \"a clearly defined and serious injury.\" United States v. Wecht, 484 F.3d 194, 211 (3d Cir. 2007) (citation omitted). The Court should also ensure that the proposed restriction is \"no broader than is necessary\" to protect that interest, and must consider the impact that the restriction may have \"on a defendant's due process right to prepare and present a full defense at trial.\" United States v. Lindh, 198 F. Supp. 2d 739, 742 (E.D. Va. 2002). Throughout its letter, the government inverts this standard, claiming that the burden is on the defense (which,\nDOJ-OGR-00001685",
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      "content": "Case 1:20-cr-00330-AJN Document 35 Filed 07/29/20 Page 1 of 5",
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      "content": "COHEN & GRESSER LLP\n800 Third Avenue\nNew York, NY 10022\n+1 212 957 7600 phone\nwww.cohengresser.com",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Mark S. Cohen\n+1 (212) 957-7600\nmcohen@cohengresser.com\nChristian R. Everdell\n+1 (212) 957-7600\nceverdell@cohengresser.com",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "July 29, 2020",
      "position": "top"
    },
    {
      "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": "top"
    },
    {
      "type": "printed",
      "content": "Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Dear Judge Nathan:\nOn behalf of our client, Ghislaine Maxwell, we respectfully submit this letter to reply to the government's response letter and submission regarding the proposed protective order in the above-captioned case, dated July 28, 2020 (\"Government's Response\" or \"Gov't Resp.\") (Dkt. 33).",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The parties have met and conferred, resolving nearly all the issues relating to the proposed protective order. The parties agree that there are two areas of dispute as to which we require guidance from the Court. As noted in our opening letter and below, we respectfully submit that the arguments made by the government are unavailing, and that the defense's proposed protective order, attached as Exhibit A to our initial submission (Dkt. 29), should be entered by the Court.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "1. Referencing Individuals Who Have Publicly Identified Themselves",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The starting point for evaluating the scope of a proposed protective order is whether there are valid privacy interests at issue. It is the government's burden to establish \"good cause\" that disclosure will cause \"a clearly defined and serious injury.\" United States v. Wecht, 484 F.3d 194, 211 (3d Cir. 2007) (citation omitted). The Court should also ensure that the proposed restriction is \"no broader than is necessary\" to protect that interest, and must consider the impact that the restriction may have \"on a defendant's due process right to prepare and present a full defense at trial.\" United States v. Lindh, 198 F. Supp. 2d 739, 742 (E.D. Va. 2002). Throughout its letter, the government inverts this standard, claiming that the burden is on the defense (which,",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00001685",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Mark S. Cohen",
      "Christian R. Everdell",
      "Alison J. Nathan",
      "Ghislaine Maxwell"
    ],
    "organizations": [
      "COHEN & GRESSER LLP",
      "United States District Court",
      "Southern District of New York"
    ],
    "locations": [
      "New York",
      "NY",
      "United States"
    ],
    "dates": [
      "July 29, 2020",
      "July 28, 2020"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "Document 35",
      "20 Cr. 330 (AJN)",
      "Dkt. 33",
      "Dkt. 29"
    ]
  },
  "additional_notes": "The document appears to be a formal letter from COHEN & GRESSER LLP to the Honorable Alison J. Nathan regarding the case United States v. Ghislaine Maxwell. The letter discusses the proposed protective order and the government's response. The document is well-formatted and free of significant damage or redactions."
}