{
  "document_metadata": {
    "page_number": "1",
    "document_number": "243",
    "date": "April 22, 2021",
    "document_type": "Court Document",
    "has_handwriting": false,
    "has_stamps": true
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 243 Filed 04/23/21 Page 1 of 5\n\nHADDON MORGAN FOREMAN\nApril 22, 2021\n\nThe Hon. Alison J. Nathan\nUnited States District Court Judge\nSouthern District of New York\n40 Foley Square\nNew York, NY 10007\n\nRe: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)\nResponse to Dkt. No. 227, Government's April 21, 2021 Letter re Ms. Maxwell's Motions to Suppress\n\nDear Judge Nathan:\n\nWe write in response to the government's letter about Ms. Maxwell's pending motions to suppress and request for evidentiary hearing (Dkt. No. 227), and this Court's order stating an intent to defer resolution of those motions and that request until after the trial on the non-perjury counts (Dkt. No. 231). Although we appreciate the need to streamline the pretrial process and the desire to efficiently resolve the pending disputes, we do not agree that the government's letter provides an adequate basis to defer resolution of Ms. Maxwell's motions.\n\nWe understand the Court's desire to maintain the status quo relating to the defense motions, but the government's response gives Ms. Maxwell no confidence that the government shares this understanding. Indeed, the government's vague assurances are insufficient to safeguard Ms. Maxwell's constitutional rights, to guarantee the government will not benefit from its unconstitutional conduct, and to ensure that Ms. Maxwell's is not deprived of due process through the introduction and use of evidence that itself was obtained in violation of due process.\n\nDOJ-OGR-00003967",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 243 Filed 04/23/21 Page 1 of 5",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "HADDON MORGAN FOREMAN",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "April 22, 2021",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The Hon. Alison J. Nathan\nUnited States District Court Judge\nSouthern District of New York\n40 Foley Square\nNew York, NY 10007",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)\nResponse to Dkt. No. 227, Government's April 21, 2021 Letter re Ms. Maxwell's Motions to Suppress",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Dear Judge Nathan:",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "We write in response to the government's letter about Ms. Maxwell's pending motions to suppress and request for evidentiary hearing (Dkt. No. 227), and this Court's order stating an intent to defer resolution of those motions and that request until after the trial on the non-perjury counts (Dkt. No. 231). Although we appreciate the need to streamline the pretrial process and the desire to efficiently resolve the pending disputes, we do not agree that the government's letter provides an adequate basis to defer resolution of Ms. Maxwell's motions.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "We understand the Court's desire to maintain the status quo relating to the defense motions, but the government's response gives Ms. Maxwell no confidence that the government shares this understanding. Indeed, the government's vague assurances are insufficient to safeguard Ms. Maxwell's constitutional rights, to guarantee the government will not benefit from its unconstitutional conduct, and to ensure that Ms. Maxwell's is not deprived of due process through the introduction and use of evidence that itself was obtained in violation of due process.",
      "position": "middle"
    },
    {
      "type": "stamp",
      "content": "USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC #: DATE FILED: 4/23/2021",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Jeffrey S. Pagliuca\nHaddon, Morgan and Foreman, P.C\nEast 10th Avenue\nDenver, Colorado 80203\nPH 303.831.7364 FX 303.832.2628\nwww.hmtlaw.com\njpagliuca@hmtlaw.com",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00003967",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ghislaine Maxwell",
      "Jeffrey S. Pagliuca"
    ],
    "organizations": [
      "Haddon Morgan Foreman",
      "United States District Court",
      "Southern District of New York"
    ],
    "locations": [
      "New York",
      "Denver",
      "Colorado"
    ],
    "dates": [
      "April 22, 2021",
      "April 21, 2021",
      "04/23/21"
    ],
    "reference_numbers": [
      "20 Cr. 330 (AJN)",
      "Dkt. No. 227",
      "Dkt. No. 231",
      "DOJ-OGR-00003967"
    ]
  },
  "additional_notes": "The document appears to be a court filing in the case United States v. Ghislaine Maxwell. The document is a letter from Jeffrey S. Pagliuca to Judge Alison J. Nathan, responding to the government's letter regarding Ghislaine Maxwell's motions to suppress. The document is stamped as being electronically filed with the USDC SDNY on April 23, 2021."
}