{
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    "page_number": "6",
    "document_number": "52",
    "date": "09/02/20",
    "document_type": "court document",
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  "full_text": "Case 1:20-cr-00330-AJN Document 52 Filed 09/02/20 Page 6 of 8\nThe Honorable Alison J. Nathan\nAugust 17, 2020\nPage 6\nThere are at least three compelling reasons to modify the Protective Order. First, [REDACTED]\nThe partial secrecy surrounding the Material has also fundamentally undermined the fairness of the adversarial process. Although the grand jury subpoena and government investigation were known to [REDACTED]\n\"The rule does not impose any obligation of secrecy on witnesses.\" Fed. R. Crim. P. 6, Advisory Committee Note to Subdivision 6(e)2. [REDACTED]\nToo many questions remain unanswered including exactly what was said between the government and [REDACTED], when was it said, and precisely what was turned over.\nWithout the ability to use the Material in the very limited fashion proposed Ms. Maxwell she is unfairly disadvantaged [REDACTED]\nMoreover, instead of candidly revealing the fact of the subpoena [REDACTED]\nSecond, [REDACTED]\nDOJ-OGR-00001757",
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      "content": "Case 1:20-cr-00330-AJN Document 52 Filed 09/02/20 Page 6 of 8",
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    {
      "type": "printed",
      "content": "The Honorable Alison J. Nathan\nAugust 17, 2020\nPage 6",
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    },
    {
      "type": "printed",
      "content": "There are at least three compelling reasons to modify the Protective Order. First, [REDACTED]",
      "position": "body"
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    {
      "type": "printed",
      "content": "The partial secrecy surrounding the Material has also fundamentally undermined the fairness of the adversarial process. Although the grand jury subpoena and government investigation were known to [REDACTED]",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "\"The rule does not impose any obligation of secrecy on witnesses.\" Fed. R. Crim. P. 6, Advisory Committee Note to Subdivision 6(e)2. [REDACTED]",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Too many questions remain unanswered including exactly what was said between the government and [REDACTED], when was it said, and precisely what was turned over.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Without the ability to use the Material in the very limited fashion proposed Ms. Maxwell she is unfairly disadvantaged [REDACTED]",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Moreover, instead of candidly revealing the fact of the subpoena [REDACTED]",
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    },
    {
      "type": "printed",
      "content": "Second, [REDACTED]",
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    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00001757",
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  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ms. Maxwell"
    ],
    "organizations": [
      "DOJ"
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    "locations": [],
    "dates": [
      "August 17, 2020",
      "09/02/20"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "Document 52",
      "DOJ-OGR-00001757"
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  "additional_notes": "The document contains redactions, likely due to sensitive information. The text is mostly printed, with no visible handwriting or stamps."
}