{
  "document_metadata": {
    "page_number": "5",
    "document_number": "140",
    "date": "02/04/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
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  "full_text": "Case 1:20-cr-00330-AJN Document 140 Filed 02/04/21 Page 5 of 22\n\nGhislaine Maxwell moves under the Fourth Amendment, Martindell v. Int'l Tel. & Tel. Corp., 594 F.2d 291 (2d Cir. 1979), and the Fifth Amendment, to suppress all evidence the government obtained from a grand jury subpoena it issued to _______________ and to dismiss Counts Five and Six, which are the fruits of that unlawful subpoena.\n\nFACTUAL BACKGROUND\n\nMs. Maxwell's Motion under the Due Process Clause to Suppress and Dismiss Counts 5 and 6 sets forth the facts relevant to this motion. Ms. Maxwell incorporates those facts by reference here.\n\nIn summary, the government obtained _______________ file, including the _______________, by way of a grand jury subpoena enforced through an ex parte proceeding before ______________. Although the government claimed not to know what was in _______________, and that _______________ had no role in instigating the investigation of Maxwell, both of these representations to _______________ were false.\n\nIn turn, the government issued a _______________ in the _____________. See Motion under the Due Process Clause to Suppress and Dismiss Counts 5 and 6, Ex. C, at 3. The government could have been, but was not, more targeted in its approach. The government has not provided Maxwell with a copy of the subpoena, but the record shows that the subpoena was incredibly broad and, as explained below, ultimately unlawful.\n\nThe subpoena violated the Fourth Amendment because it was overbroad and because it effected a warrantless search and seizure of material in which Maxwell had a reasonable expectation of privacy. Moreover, by securing a modification of the Protective Order through a secret, ex parte proceeding, the government violated Martindell v. Int'l Tel. & Tel. Corp., 594\n\n1\nDOJ-OGR-00002553",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 140 Filed 02/04/21 Page 5 of 22",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Ghislaine Maxwell moves under the Fourth Amendment, Martindell v. Int'l Tel. & Tel. Corp., 594 F.2d 291 (2d Cir. 1979), and the Fifth Amendment, to suppress all evidence the government obtained from a grand jury subpoena it issued to _______________ and to dismiss Counts Five and Six, which are the fruits of that unlawful subpoena.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "FACTUAL BACKGROUND",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Ms. Maxwell's Motion under the Due Process Clause to Suppress and Dismiss Counts 5 and 6 sets forth the facts relevant to this motion. Ms. Maxwell incorporates those facts by reference here.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "In summary, the government obtained _______________ file, including the _______________, by way of a grand jury subpoena enforced through an ex parte proceeding before ______________. Although the government claimed not to know what was in _______________, and that _______________ had no role in instigating the investigation of Maxwell, both of these representations to _______________ were false.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "In turn, the government issued a _______________ in the _____________. See Motion under the Due Process Clause to Suppress and Dismiss Counts 5 and 6, Ex. C, at 3. The government could have been, but was not, more targeted in its approach. The government has not provided Maxwell with a copy of the subpoena, but the record shows that the subpoena was incredibly broad and, as explained below, ultimately unlawful.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The subpoena violated the Fourth Amendment because it was overbroad and because it effected a warrantless search and seizure of material in which Maxwell had a reasonable expectation of privacy. Moreover, by securing a modification of the Protective Order through a secret, ex parte proceeding, the government violated Martindell v. Int'l Tel. & Tel. Corp., 594",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "1\nDOJ-OGR-00002553",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Ghislaine Maxwell"
    ],
    "organizations": [],
    "locations": [],
    "dates": [
      "02/04/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "Document 140",
      "DOJ-OGR-00002553"
    ]
  },
  "additional_notes": "The document contains redactions, likely due to sensitive information. The text is a court document related to Ghislaine Maxwell's case, discussing legal motions and subpoenas."
}