{
  "document_metadata": {
    "page_number": "1",
    "document_number": "241",
    "date": "April 23, 2021",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": true
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 241 Filed 04/23/21 Page 1 of 2\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 23, 2021\nUSDC SDNY\nDOCUMENT\nELECTRONICALLY FILED\nDOC #:\nDATE FILED: 4/23/21\nBY 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:\nThe Government respectfully submits this letter in response to the Court's Order dated April 21, 2021, which directed the Government to submit any requests for redaction of information contained in filings regarding the defense's proposed Rule 17(c) subpoena. (Dkt. No. 226). After reviewing the relevant filings, the Government seeks a limited number of redactions, which are narrowly tailored to protect the privacy interests of third parties. In particular, the Government respectfully requests that the Court permit the redaction of the names and identifying information of particular third parties referenced in the defense's response to the objections of Boies Schiller Flexner LLP (\"BSF\") to the defense's proposed Rule 17(c) subpoena, BSF's reply, and the April 19, 2021 joint letter addressing the redactions to those same documents. Today the Government is submitting to the Court by email its proposed redactions to those documents, which the Government respectfully requests be filed under seal.\nThese proposed redactions are consistent with the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Although these documents are judicial documents that are subject to the common law presumption of access, the\nDOJ-OGR-00003963",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 241 Filed 04/23/21 Page 1 of 2",
      "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 23, 2021",
      "position": "header"
    },
    {
      "type": "stamp",
      "content": "USDC SDNY\nDOCUMENT\nELECTRONICALLY FILED\nDOC #:\nDATE FILED: 4/23/21",
      "position": "margin"
    },
    {
      "type": "printed",
      "content": "BY 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": "body"
    },
    {
      "type": "printed",
      "content": "Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Dear Judge Nathan:\nThe Government respectfully submits this letter in response to the Court's Order dated April 21, 2021, which directed the Government to submit any requests for redaction of information contained in filings regarding the defense's proposed Rule 17(c) subpoena. (Dkt. No. 226). After reviewing the relevant filings, the Government seeks a limited number of redactions, which are narrowly tailored to protect the privacy interests of third parties. In particular, the Government respectfully requests that the Court permit the redaction of the names and identifying information of particular third parties referenced in the defense's response to the objections of Boies Schiller Flexner LLP (\"BSF\") to the defense's proposed Rule 17(c) subpoena, BSF's reply, and the April 19, 2021 joint letter addressing the redactions to those same documents. Today the Government is submitting to the Court by email its proposed redactions to those documents, which the Government respectfully requests be filed under seal.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "These proposed redactions are consistent with the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Although these documents are judicial documents that are subject to the common law presumption of access, the",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00003963",
      "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 23, 2021",
      "April 21, 2021",
      "April 19, 2021"
    ],
    "reference_numbers": [
      "20 Cr. 330 (AJN)",
      "Dkt. No. 226",
      "435 F.3d 110 (2d Cir. 2006)",
      "DOJ-OGR-00003963"
    ]
  },
  "additional_notes": "The document appears to be a formal letter from the U.S. Department of Justice to the Honorable Alison J. Nathan, regarding the case United States v. Ghislaine Maxwell. The letter discusses the government's request for redactions in certain documents related to the case."
}