{
  "document_metadata": {
    "page_number": "1",
    "document_number": "48",
    "date": "August 24, 2020",
    "document_type": "Letter Motion",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 48 Filed 08/24/20 Page 1 of 2\nHaddon, Morgan and Foreman, P.C\nLaura A. Menninger\n150 East 10th Avenue\nDenver, Colorado 80203\nPH 303.831.7364 FX 303.832.2628\nwww.hmflaw.com\nlmenninger@hmflaw.com\nAugust 24, 2020\nVIA ECF\nThe Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\n40 Foley Square\nNew York, New York 10007\nRe: Request to File Under Seal: Proposed Redactions to Request to Modify Protective Order and Reply in Support Thereof\nUnited States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)\nDear Judge Nathan:\nThis is a letter motion to file under seal Ms. Maxwell's Proposed Redactions to Request to Modify Protective Order (\"Proposed Redactions\") as well as her Reply in Support of Request to Modify Protective Order (\"Reply\").\nThe Protective Order in this case states:\nThe Defendant, Defense Counsel, Defense Staff, Defense Experts/Advisors, Potential Defense Witnesses, and Other Authorized Persons are prohibited from filing publicly as an attachment to a filing or excerpted within a filing any Confidential Information or Highly Confidential Information referenced in the Discovery, unless authorized by the Government in writing or by Order of the Court. Any such filings must be filed under seal, unless authorized by the Government in writing or by Order of the Court.\nSee Protective Order (Doc. 36) at ¶ 15.\nThe Proposed Redactions and the Reply contain content designated as Confidential Information by the Government under the terms of the Protective Order.\nMs. Maxwell therefore requests permission to file the Proposed Redactions and Reply under seal, at least until such time as the Court has ruled on the proposed redactions set forth therein.\nDOJ-OGR-00001741",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 48 Filed 08/24/20 Page 1 of 2",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Haddon, Morgan and Foreman, P.C\nLaura A. Menninger\n150 East 10th Avenue\nDenver, Colorado 80203\nPH 303.831.7364 FX 303.832.2628\nwww.hmflaw.com\nlmenninger@hmflaw.com",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "August 24, 2020\nVIA ECF",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\n40 Foley Square\nNew York, New York 10007",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Re: Request to File Under Seal: Proposed Redactions to Request to Modify Protective Order and Reply in Support Thereof\nUnited States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Dear Judge Nathan:\nThis is a letter motion to file under seal Ms. Maxwell's Proposed Redactions to Request to Modify Protective Order (\"Proposed Redactions\") as well as her Reply in Support of Request to Modify Protective Order (\"Reply\").",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The Protective Order in this case states:\nThe Defendant, Defense Counsel, Defense Staff, Defense Experts/Advisors, Potential Defense Witnesses, and Other Authorized Persons are prohibited from filing publicly as an attachment to a filing or excerpted within a filing any Confidential Information or Highly Confidential Information referenced in the Discovery, unless authorized by the Government in writing or by Order of the Court. Any such filings must be filed under seal, unless authorized by the Government in writing or by Order of the Court.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "See Protective Order (Doc. 36) at ¶ 15.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The Proposed Redactions and the Reply contain content designated as Confidential Information by the Government under the terms of the Protective Order.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Ms. Maxwell therefore requests permission to file the Proposed Redactions and Reply under seal, at least until such time as the Court has ruled on the proposed redactions set forth therein.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00001741",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ghislaine Maxwell",
      "Laura A. Menninger"
    ],
    "organizations": [
      "Haddon, Morgan and Foreman, P.C",
      "United States District Court",
      "Southern District of New York"
    ],
    "locations": [
      "Denver",
      "Colorado",
      "New York"
    ],
    "dates": [
      "August 24, 2020"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "Document 48",
      "20 Cr. 330 (AJN)",
      "Doc. 36",
      "DOJ-OGR-00001741"
    ]
  },
  "additional_notes": "The document appears to be a formal letter motion filed with the court, requesting permission to file certain documents under seal. The document is well-formatted and free of significant damage or redactions."
}