{
  "document_metadata": {
    "page_number": "1",
    "document_number": "80",
    "date": "12/02/20",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 80 Filed 12/02/20 Page 1 of 1\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\nDecember 2, 2020\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 defense requests for sealing and for an in camera hearing in connection with the defendant's anticipated renewed application for bail. The Government has reviewed the proposed redactions to the defense letters dated November 25, 2020 and November 30, 2020. Because those proposed redactions are narrowly tailored to protect the privacy interests of third parties, the Government has no objection to the defense's proposed redactions. The Government objects, however, to the defense request for a sealed in camera hearing to discuss further sealing requests from the defense. As demonstrated by the defense's recent letters, any request for sealing of third party information can be made in writing with narrowly tailored redactions. Based on defense counsel's proffers regarding the potential harms that may come from publicly identifying proposed cosigners, the Government has no objection to the redaction and sealed filing of any identifying information for those individuals. Given the availability of redacted filings, the Government sees no reason for an entire hearing to be conducted without the opportunity for the public or the victims in this case to observe. Indeed, given that crime victims have a statutory right to be present and heard at any proceeding regarding the defendant's \"release,\" 18 U.S.C. § 3771(a)(4), the Government would object to any proceeding addressing aspects of a renewed bail application that was conducted entirely in camera.\nRespectfully submitted,\nAUDREY STRAUSS\nActing United States Attorney\nBy: s/\nMaurene Comey / Alison Moe / Lara Pomerantz\nAssistant United States Attorneys\nSouthern District of New York\nTel: (212) 637-2324\nCc: All Counsel of Record (By ECF)\nDOJ-OGR-00001846",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 80 Filed 12/02/20 Page 1 of 1",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "U.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\nDecember 2, 2020",
      "position": "header"
    },
    {
      "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": "top"
    },
    {
      "type": "printed",
      "content": "Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Dear Judge Nathan:\nThe Government respectfully submits this letter in response to the defense requests for sealing and for an in camera hearing in connection with the defendant's anticipated renewed application for bail. The Government has reviewed the proposed redactions to the defense letters dated November 25, 2020 and November 30, 2020. Because those proposed redactions are narrowly tailored to protect the privacy interests of third parties, the Government has no objection to the defense's proposed redactions. The Government objects, however, to the defense request for a sealed in camera hearing to discuss further sealing requests from the defense. As demonstrated by the defense's recent letters, any request for sealing of third party information can be made in writing with narrowly tailored redactions. Based on defense counsel's proffers regarding the potential harms that may come from publicly identifying proposed cosigners, the Government has no objection to the redaction and sealed filing of any identifying information for those individuals. Given the availability of redacted filings, the Government sees no reason for an entire hearing to be conducted without the opportunity for the public or the victims in this case to observe. Indeed, given that crime victims have a statutory right to be present and heard at any proceeding regarding the defendant's \"release,\" 18 U.S.C. § 3771(a)(4), the Government would object to any proceeding addressing aspects of a renewed bail application that was conducted entirely in camera.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Respectfully submitted,\nAUDREY STRAUSS\nActing United States Attorney\nBy: s/\nMaurene Comey / Alison Moe / Lara Pomerantz\nAssistant United States Attorneys\nSouthern District of New York\nTel: (212) 637-2324",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "Cc: All Counsel of Record (By ECF)",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00001846",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ghislaine Maxwell",
      "Audrey Strauss",
      "Maurene Comey",
      "Alison Moe",
      "Lara Pomerantz"
    ],
    "organizations": [
      "U.S. Department of Justice",
      "United States Attorney",
      "United States District Court",
      "Southern District of New York"
    ],
    "locations": [
      "New York",
      "United States"
    ],
    "dates": [
      "December 2, 2020",
      "November 25, 2020",
      "November 30, 2020"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "20 Cr. 330 (AJN)",
      "DOJ-OGR-00001846"
    ]
  },
  "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 response to the defense's requests for sealing and an in-camera hearing. The document is typed and contains no handwritten text or stamps."
}