{
  "document_metadata": {
    "page_number": "96",
    "document_number": "204",
    "date": "04/16/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 96 of 239\n\nMartindell was applicable. (Id. at 3). She stated that were the Government's application disclosed to the parties, \"Maxwell would protest\" and argue that the Government lacked standing as it was not a party to the protective order. (Id. at 8). In response to questions from Chief Judge McMahon, the Government explained that the protective order, on its face, did not implicate the types of confidential business information or trade secrets ordinarily considered by courts in conducting the Martindell balancing test. (Id. at 13).\n\nChief Judge McMahon stated that the protective order did not contain a provision allowing a party to the order to disclose materials requested by law enforcement without permission of the court, noting her understanding that \"it may have been negotiated out.\" (Id. at 14-15). The court inquired whether the Government's position was that \"reliance on the nondisclosure of confidential materials to law enforcement in connection with a grand jury subpoena that has been duly authorized would be unreasonable.\" (Id. at 14). The Government responded in the affirmative, stating that the Government believed a provision precluding compliance with a law enforcement request would be void for public policy. (Id. at 15). The Government further cited Chemical Bank in support of the proposition that it would be unreasonable to rely on a protective order provision that barred the disclosure of information to law enforcement. (Id. at 15-16).\n\nIn response to questions about the breadth of the subpoena, the Government explained that it was \"essentially unable to significantly narrow the request for information . . . . We have either little or no additional information than the Court does in terms of what materials there are [and] who was deposed.\" (Id. at 17). In response to Chief Judge McMahon's question about the privacy interests implicated by the protective order, (id. at 16-17), the Government also noted that it was dissimilar to an ordinary third-party intervenor in that it would be \"extremely restricted\" in its use\n\n69\n\nDOJ-OGR-00003030",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 96 of 239",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Martindell was applicable. (Id. at 3). She stated that were the Government's application disclosed to the parties, \"Maxwell would protest\" and argue that the Government lacked standing as it was not a party to the protective order. (Id. at 8). In response to questions from Chief Judge McMahon, the Government explained that the protective order, on its face, did not implicate the types of confidential business information or trade secrets ordinarily considered by courts in conducting the Martindell balancing test. (Id. at 13).",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Chief Judge McMahon stated that the protective order did not contain a provision allowing a party to the order to disclose materials requested by law enforcement without permission of the court, noting her understanding that \"it may have been negotiated out.\" (Id. at 14-15). The court inquired whether the Government's position was that \"reliance on the nondisclosure of confidential materials to law enforcement in connection with a grand jury subpoena that has been duly authorized would be unreasonable.\" (Id. at 14). The Government responded in the affirmative, stating that the Government believed a provision precluding compliance with a law enforcement request would be void for public policy. (Id. at 15). The Government further cited Chemical Bank in support of the proposition that it would be unreasonable to rely on a protective order provision that barred the disclosure of information to law enforcement. (Id. at 15-16).",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "In response to questions about the breadth of the subpoena, the Government explained that it was \"essentially unable to significantly narrow the request for information . . . . We have either little or no additional information than the Court does in terms of what materials there are [and] who was deposed.\" (Id. at 17). In response to Chief Judge McMahon's question about the privacy interests implicated by the protective order, (id. at 16-17), the Government also noted that it was dissimilar to an ordinary third-party intervenor in that it would be \"extremely restricted\" in its use",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "69",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00003030",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Maxwell",
      "Chief Judge McMahon"
    ],
    "organizations": [
      "Chemical Bank",
      "Government"
    ],
    "locations": [],
    "dates": [
      "04/16/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 204",
      "DOJ-OGR-00003030"
    ]
  },
  "additional_notes": "The document appears to be a court transcript or legal document related to a case involving Maxwell. The text is mostly printed, with no visible handwriting or stamps. The document is well-formatted and easy to read."
}