{
  "document_metadata": {
    "page_number": "1",
    "document_number": "31",
    "date": "07/27/20",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": true
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 31 Filed 07/27/20 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\nJuly 27, 2020\nVIA 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 to request the opportunity to respond to defense counsel's letter motion seeking the entry of a protective order, which was filed this morning. The Government and defense counsel were in discussions - as recently as 6 p.m. last night - in the hopes of jointly proposing a protective order. Until seeing the filing on ECF this morning, the Government had understood those discussions to be ongoing. In light of the defense's letter, however, the Government respectfully requests until 5 p.m. tomorrow to submit a response.\nRespectfully submitted,\nAUDREY STRAUSS\nActing United States Attorney\nBy: /s/\nAlex Rossmiller / Alison Moe / Maurene Comey\nAssistant United States Attorneys\nSouthern District of New York\nTel: (212) 637-2324\nCc: All counsel of record (by ECF)\nDOJ-OGR-00001662",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 31 Filed 07/27/20 Page 1 of 1",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "U.S. Department of Justice\nUnited States Attorney\nSouthern District of New York",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The Silvio J. Mollo Building\nOne Saint Andrew's Plaza\nNew York, New York 10007",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "July 27, 2020",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "VIA ECF",
      "position": "middle"
    },
    {
      "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:",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The Government respectfully submits this letter to request the opportunity to respond to defense counsel's letter motion seeking the entry of a protective order, which was filed this morning. The Government and defense counsel were in discussions - as recently as 6 p.m. last night - in the hopes of jointly proposing a protective order. Until seeing the filing on ECF this morning, the Government had understood those discussions to be ongoing. In light of the defense's letter, however, the Government respectfully requests until 5 p.m. tomorrow to submit a response.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Respectfully submitted,\nAUDREY STRAUSS\nActing United States Attorney",
      "position": "middle"
    },
    {
      "type": "handwritten",
      "content": "/s/",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Alex Rossmiller / Alison Moe / Maurene Comey\nAssistant United States Attorneys\nSouthern District of New York\nTel: (212) 637-2324",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Cc: All counsel of record (by ECF)",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00001662",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ghislaine Maxwell",
      "Audrey Strauss",
      "Alex Rossmiller",
      "Alison Moe",
      "Maurene Comey"
    ],
    "organizations": [
      "U.S. Department of Justice",
      "United States Attorney",
      "United States District Court"
    ],
    "locations": [
      "New York"
    ],
    "dates": [
      "July 27, 2020"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "20 Cr. 330 (AJN)",
      "DOJ-OGR-00001662"
    ]
  },
  "additional_notes": "The document is a letter from the U.S. Department of Justice to the Honorable Alison J. Nathan regarding the case United States v. Ghislaine Maxwell. The letter is dated July 27, 2020, and is signed by Audrey Strauss, Acting United States Attorney. The document contains a stamp from the U.S. Department of Justice."
}