{
  "document_metadata": {
    "page_number": "1",
    "document_number": "278",
    "date": "05/12/21",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": true
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 278 Filed 05/12/21 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\nMay 12, 2021\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 May 10, 2021, which directed the Government to propose and justify any requests for redaction of the defendant's memorandum in support of her supplemental pre-trial motions and exhibits. (Dkt. No. 274).\nAfter reviewing the defense's memorandum, the Government seeks a limited number of redactions. 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 the defense's memorandum in support of her supplemental pre-trial motions is a judicial document subject to the common law presumption of access, the proposed redactions are narrowly tailored to protect the privacy interests of victims and third parties referenced in the document. These redactions are thus consistent with similar, tailored redactions permitted by the Court in this case to protect the privacy interests of third parties. (See, e.g., Dkt. No. 168, 232). Today the Government is submitting to the Court by email its proposed redactions to the defense's memorandum, which the Government respectfully requests be filed under seal.\nDOJ-OGR-00004123",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 278 Filed 05/12/21 Page 1 of 2",
      "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",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "May 12, 2021",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "BY ECF",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The 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": "middle"
    },
    {
      "type": "printed",
      "content": "Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Dear Judge Nathan:\nThe Government respectfully submits this letter in response to the Court's Order dated May 10, 2021, which directed the Government to propose and justify any requests for redaction of the defendant's memorandum in support of her supplemental pre-trial motions and exhibits. (Dkt. No. 274).\nAfter reviewing the defense's memorandum, the Government seeks a limited number of redactions. 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 the defense's memorandum in support of her supplemental pre-trial motions is a judicial document subject to the common law presumption of access, the proposed redactions are narrowly tailored to protect the privacy interests of victims and third parties referenced in the document. These redactions are thus consistent with similar, tailored redactions permitted by the Court in this case to protect the privacy interests of third parties. (See, e.g., Dkt. No. 168, 232). Today the Government is submitting to the Court by email its proposed redactions to the defense's memorandum, which the Government respectfully requests be filed under seal.",
      "position": "middle"
    },
    {
      "type": "stamp",
      "content": "DOJ-OGR-00004123",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ghislaine Maxwell"
    ],
    "organizations": [
      "U.S Department of Justice",
      "United States Attorney",
      "United States District Court",
      "Second Circuit"
    ],
    "locations": [
      "New York",
      "Southern District of New York"
    ],
    "dates": [
      "May 12, 2021",
      "May 10, 2021"
    ],
    "reference_numbers": [
      "20 Cr. 330 (AJN)",
      "Dkt. No. 274",
      "Dkt. No. 168",
      "Dkt. No. 232",
      "DOJ-OGR-00004123"
    ]
  },
  "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 proposed redactions to the defendant's memorandum and is stamped with a DOJ reference number."
}