{
  "document_metadata": {
    "page_number": "14",
    "document_number": "148",
    "date": "02/04/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 148 Filed 02/04/21 Page 14 of 23\n(Dkt. 68) (emphasis added). Accordingly, the Court should order the government to produce unredacted copies of these reports.\nB. The Diary Pages\nThe government also produced in discovery\nIn opposing Ms. Maxwell's applications for bail, the government relied heavily on the diary entries as contemporaneous documentary corroboration of their case against Ms. Maxwell. Yet\nWe asked the government to produce a complete copy of the diary. The government responded that\nIn its opposition to Ms. Maxwell's second bail application, the government further represented that\nIf the government will not obtain and produce the rest of the diary, Ms. Maxwell will have to issue a subpoena to the diary's author. But because the government refuses to disclose her name to the defense, we don't know who to subpoena and will not know until it is too late to obtain the diary in time for trial.\nAccordingly, we request the Court to order the government to produce a complete copy of the diary or, in the alternative, to identify the name of the diary's author.\n10\nDOJ-OGR-00002707",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 148 Filed 02/04/21 Page 14 of 23",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "(Dkt. 68) (emphasis added). Accordingly, the Court should order the government to produce unredacted copies of these reports.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "B. The Diary Pages",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The government also produced in discovery\nIn opposing Ms. Maxwell's applications for bail, the government relied heavily on the diary entries as contemporaneous documentary corroboration of their case against Ms. Maxwell. Yet\nWe asked the government to produce a complete copy of the diary. The government responded that\nIn its opposition to Ms. Maxwell's second bail application, the government further represented that\nIf the government will not obtain and produce the rest of the diary, Ms. Maxwell will have to issue a subpoena to the diary's author. But because the government refuses to disclose her name to the defense, we don't know who to subpoena and will not know until it is too late to obtain the diary in time for trial.\nAccordingly, we request the Court to order the government to produce a complete copy of the diary or, in the alternative, to identify the name of the diary's author.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "10",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00002707",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Ms. Maxwell"
    ],
    "organizations": [
      "Court",
      "government"
    ],
    "locations": [],
    "dates": [
      "02/04/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "148",
      "68",
      "DOJ-OGR-00002707"
    ]
  },
  "additional_notes": "The document contains redactions, indicated by black bars over certain text."
}