{
  "document_metadata": {
    "page_number": "17",
    "document_number": "134",
    "date": "02/04/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 134 Filed 02/04/21 Page 17 of 23\nexpressly invoked the assurances of the Protective Order. So did the district court in permitting these intrusions and ordering Maxwell to sit for a second deposition. Maxwell likewise relied on the Protective Order in choosing to render such intimate details, rather than assert her Fifth Amendment privilege as she had every right to do.\nAnd why shouldn't Maxwell have relied on the Protective Order? The central protection in the Order was that none of Maxwell's answers could be disclosed to the government. Boies Schiller had expressly sought a law enforcement exception but was rebuffed. Instead, the law firm was required either to return the confidential material or, at Maxwell's option, to destroy it. Maxwell had every reason to take that assurance seriously, even if did not.\n2. The government circumvented the protective order.\nFaced with a duly entered Protective Order—which quite deliberately omitted any “law enforcement” exception—the government had lawful options to pursue the confidential Giuffre discovery. It could have moved to intervene in the civil case and to amend the Protective Order. It could have issued a subpoena for the materials and given Maxwell an opportunity to respond. Martindell, 594 F.2d at 294. It could even have applied for a search warrant, assuming (counterfactually) that it could show probable cause in support of such a warrant.\nThe government did none of those things. Instead, . This was not among the lawful options available to the government.\nIt cannot fairly be disputed that ruling to amend the Protective Order was based on the government's misrepresentations. Immediately before issuing her decision, held a hearing with the sole purpose of asking the prosecutor, stated reason for so inquiring was to ensure that the government and had not coordinated as the parties 12\nDOJ-OGR-00002364",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 134 Filed 02/04/21 Page 17 of 23",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "expressly invoked the assurances of the Protective Order. So did the district court in permitting these intrusions and ordering Maxwell to sit for a second deposition. Maxwell likewise relied on the Protective Order in choosing to render such intimate details, rather than assert her Fifth Amendment privilege as she had every right to do.\nAnd why shouldn't Maxwell have relied on the Protective Order? The central protection in the Order was that none of Maxwell's answers could be disclosed to the government. Boies Schiller had expressly sought a law enforcement exception but was rebuffed. Instead, the law firm was required either to return the confidential material or, at Maxwell's option, to destroy it. Maxwell had every reason to take that assurance seriously, even if did not.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "2. The government circumvented the protective order.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Faced with a duly entered Protective Order—which quite deliberately omitted any “law enforcement” exception—the government had lawful options to pursue the confidential Giuffre discovery. It could have moved to intervene in the civil case and to amend the Protective Order. It could have issued a subpoena for the materials and given Maxwell an opportunity to respond. Martindell, 594 F.2d at 294. It could even have applied for a search warrant, assuming (counterfactually) that it could show probable cause in support of such a warrant.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The government did none of those things. Instead, . This was not among the lawful options available to the government.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "It cannot fairly be disputed that ruling to amend the Protective Order was based on the government's misrepresentations. Immediately before issuing her decision, held a hearing with the sole purpose of asking the prosecutor, stated reason for so inquiring was to ensure that the government and had not coordinated as the parties",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "12",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00002364",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Maxwell",
      "Giuffre",
      "Martindell"
    ],
    "organizations": [
      "Boies Schiller"
    ],
    "locations": [],
    "dates": [
      "02/04/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "Document 134",
      "DOJ-OGR-00002364"
    ]
  },
  "additional_notes": "The document appears to be a court filing with redactions."
}