{
  "document_metadata": {
    "page_number": "1",
    "document_number": "34",
    "date": "07/28/20",
    "document_type": "Affidavit of Certification",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 34 Filed 07/28/20 Page 1 of 2\n\nUNITED STATES DISTRICT COURT\nSOUTHERN DISTRICT OF NEW YORK\n--------------------------------------------------------------X\nUNITED STATES OF AMERICA,\n- v. -\nGHISLAINE MAXWELL,\nDefendant.\n--------------------------------------------------------------X\nSTATE OF NEW YORK\nCOUNTY OF NEW YORK\nSOUTHERN DISTRICT OF NEW YORK\nALEX ROSSMILLER, pursuant to Title 28, United States Code, Section 1746, hereby affirms under penalty of perjury:\n1. I am an Assistant United States Attorney in the Office of Audrey Strauss, Acting United States Attorney for the Southern District of New York. I am one of the Assistants who represents the Government in these proceedings.\n2. I certify pursuant to Local Criminal Rule 16.1 that the Government has conferred in good faith with counsel to the defendant, Ghislaine Maxwell, regarding the Government's proposed protective order, pursuant to Federal Rule of Criminal Procedure 16.\n3. The parties have been able to agree on most of the provisions of a protective order. However, the parties have been unable to resolve two areas of dispute.\na. First, the defendant and her counsel have objected to the Government's proposal that the defense be permitted to reference identities of witnesses and victims to prospective defense witnesses (so long as those witnesses and their counsel abstain from further disclosing or disseminating any such identities), and be permitted to reference publicly any victim",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 34 Filed 07/28/20 Page 1 of 2",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "UNITED STATES DISTRICT COURT\nSOUTHERN DISTRICT OF NEW YORK",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "UNITED STATES OF AMERICA,\n- v. -\nGHISLAINE MAXWELL,\nDefendant.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "AFFIDAVIT OF CERTIFICATION\nPURSUANT TO LOCAL\nCRIMINAL RULE 16.1",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "STATE OF NEW YORK\nCOUNTY OF NEW YORK\nSOUTHERN DISTRICT OF NEW YORK",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "ALEX ROSSMILLER, pursuant to Title 28, United States Code, Section 1746, hereby affirms under penalty of perjury:",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "1. I am an Assistant United States Attorney in the Office of Audrey Strauss, Acting United States Attorney for the Southern District of New York. I am one of the Assistants who represents the Government in these proceedings.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "2. I certify pursuant to Local Criminal Rule 16.1 that the Government has conferred in good faith with counsel to the defendant, Ghislaine Maxwell, regarding the Government's proposed protective order, pursuant to Federal Rule of Criminal Procedure 16.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "3. The parties have been able to agree on most of the provisions of a protective order. However, the parties have been unable to resolve two areas of dispute.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "a. First, the defendant and her counsel have objected to the Government's proposal that the defense be permitted to reference identities of witnesses and victims to prospective defense witnesses (so long as those witnesses and their counsel abstain from further disclosing or disseminating any such identities), and be permitted to reference publicly any victim",
      "position": "bottom"
    }
  ],
  "entities": {
    "people": [
      "Ghislaine Maxwell",
      "Alex Rossmiller",
      "Audrey Strauss"
    ],
    "organizations": [
      "UNITED STATES DISTRICT COURT",
      "UNITED STATES OF AMERICA"
    ],
    "locations": [
      "NEW YORK"
    ],
    "dates": [
      "07/28/20"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "Document 34"
    ]
  },
  "additional_notes": "The document appears to be a court filing in a criminal case, with no visible redactions or damage."
}