{
  "document_metadata": {
    "page_number": "22",
    "document_number": "311-4",
    "date": "07/02/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 311-4 Filed 07/02/21 Page 22 of 27\nTo Be Filed Under Seal\nof turning over their discovery to the government in order to coerce a settlement\"). The parties also settled just a short time before trial; such a settlement could have been occasioned, at least in part, to avoid the public disclosure of any confidential materials.\nHowever, the only thing on which Maxwell or anyone else might reasonably have relied is that Giuffre or her lawyers would not do what the defendant in Chemical Bank did—that is, forward discovery materials in their possession to prosecutors for the purpose of fomenting an investigation. But I am not faced with that situation. Nothing in this record suggests to me that Giuffre or Boies Schiller had anything to do with the Government’s decision to convene a grand jury to look into the matters that were the subject of the Giuffre Action. On the contrary—the Government has advised the Court that it contacted Boies Schiller as part of its search for parties who might have been victims in its investigation; and that Boies Schiller told the Government that it could not consensually produce at least some documents in its files because of the existence of the Protective Order. There is no evidence of “collusion,” to invoke a term of the moment, and it is quite clear that Boies Schiller did not foment the Government’s investigation.\nMoreover, the Assistant United States Attorney has represented to this Court that he has no idea what is in Boies Schiller’s files, and that for all he knows every witness who was deposed stood on his/her Fifth Amendment rights and refused to answer questions.\nThe literal terms of the Protective Order permit the court to authorize the release of Confidential Materials by parties to the Order “for good cause shown.” (Protective Order, ¶ 14.)\nAny party who read the order had to be aware that it contained no promise that Confidential Materials would forever be withheld from a prosecuting agency—especially where, as here, a duly empowered grand jury seeks their production.\n21\nSDNY_GM_00000895\nDOJ-OGR-00004945",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 311-4 Filed 07/02/21 Page 22 of 27",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "To Be Filed Under Seal",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "of turning over their discovery to the government in order to coerce a settlement\"). The parties also settled just a short time before trial; such a settlement could have been occasioned, at least in part, to avoid the public disclosure of any confidential materials.\nHowever, the only thing on which Maxwell or anyone else might reasonably have relied is that Giuffre or her lawyers would not do what the defendant in Chemical Bank did—that is, forward discovery materials in their possession to prosecutors for the purpose of fomenting an investigation. But I am not faced with that situation. Nothing in this record suggests to me that Giuffre or Boies Schiller had anything to do with the Government’s decision to convene a grand jury to look into the matters that were the subject of the Giuffre Action. On the contrary—the Government has advised the Court that it contacted Boies Schiller as part of its search for parties who might have been victims in its investigation; and that Boies Schiller told the Government that it could not consensually produce at least some documents in its files because of the existence of the Protective Order. There is no evidence of “collusion,” to invoke a term of the moment, and it is quite clear that Boies Schiller did not foment the Government’s investigation.\nMoreover, the Assistant United States Attorney has represented to this Court that he has no idea what is in Boies Schiller’s files, and that for all he knows every witness who was deposed stood on his/her Fifth Amendment rights and refused to answer questions.\nThe literal terms of the Protective Order permit the court to authorize the release of Confidential Materials by parties to the Order “for good cause shown.” (Protective Order, ¶ 14.)\nAny party who read the order had to be aware that it contained no promise that Confidential Materials would forever be withheld from a prosecuting agency—especially where, as here, a duly empowered grand jury seeks their production.",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "21",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "SDNY_GM_00000895\nDOJ-OGR-00004945",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Maxwell",
      "Giuffre"
    ],
    "organizations": [
      "Boies Schiller",
      "Government",
      "Chemical Bank",
      "Court",
      "United States Attorney"
    ],
    "locations": [],
    "dates": [
      "07/02/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "311-4",
      "22",
      "SDNY_GM_00000895",
      "DOJ-OGR-00004945"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is mostly printed, with no handwritten content or stamps visible. The document is marked 'To Be Filed Under Seal', indicating that it contains sensitive information."
}