{
  "document_metadata": {
    "page_number": "1",
    "document_number": "331",
    "date": "August 30, 2021",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 331 Filed 08/30/21 Page 1 of 5 HADDON MORGAN FOREMAN Haddon, Morgan and Foreman, P.C Jeffrey Pagliuca 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 FX 303.832.2628 www.hmflaw.com jpagliuca@hmflaw.com August 30, 2021 VIA ECF The Honorable Alison J. Nathan United States District Court Southern District of New York 40 Foley Square New York, NY 10007 Re: Response to Government Letter dated August 18, 2021, Dkt. 320, United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan, I write in response to the government's letter dated August 18, 2021, Dkt. 320, which raises two issues.1 Identities of Co-Conspirators The government first attempts to walk back its multiple concessions regarding disclosure of the identities of the unnamed co-conspirators alleged in the S2 indictment. As this Court noted, Ms. Maxwell has on at least two occasions requested such disclosure. Dkt. 317 at 12 n.1 (citing Dkt. 291 and Dkt. 293). Only after this Court ordered disclosure of the identities of the unnamed co-conspirators alleged in the S2 indictment did the government finally object. The government's objection comes too late. 1 As directed by the Court, on August 24 the parties conferred about the government's letter, but they were unable to reach an agreement on the government's requests for reconsideration. DOJ-OGR-00005019",
  "text_blocks": [
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      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 331 Filed 08/30/21 Page 1 of 5",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "HADDON MORGAN FOREMAN",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Haddon, Morgan and Foreman, P.C Jeffrey Pagliuca 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 FX 303.832.2628 www.hmflaw.com jpagliuca@hmflaw.com",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "August 30, 2021",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "VIA ECF The Honorable Alison J. Nathan United States District Court Southern District of New York 40 Foley Square New York, NY 10007 Re: Response to Government Letter dated August 18, 2021, Dkt. 320, United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan,",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "I write in response to the government's letter dated August 18, 2021, Dkt. 320, which raises two issues.1 Identities of Co-Conspirators The government first attempts to walk back its multiple concessions regarding disclosure of the identities of the unnamed co-conspirators alleged in the S2 indictment. As this Court noted, Ms. Maxwell has on at least two occasions requested such disclosure. Dkt. 317 at 12 n.1 (citing Dkt. 291 and Dkt. 293). Only after this Court ordered disclosure of the identities of the unnamed co-conspirators alleged in the S2 indictment did the government finally object. The government's objection comes too late.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "1 As directed by the Court, on August 24 the parties conferred about the government's letter, but they were unable to reach an agreement on the government's requests for reconsideration.",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00005019",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ghislaine Maxwell",
      "Jeffrey Pagliuca"
    ],
    "organizations": [
      "Haddon, Morgan and Foreman, P.C",
      "United States District Court",
      "Southern District of New York"
    ],
    "locations": [
      "Denver",
      "Colorado",
      "New York"
    ],
    "dates": [
      "August 30, 2021",
      "August 18, 2021",
      "August 24"
    ],
    "reference_numbers": [
      "Case 1:20-cr-00330-PAE",
      "Document 331",
      "Dkt. 320",
      "20 Cr. 330 (AJN)",
      "Dkt. 317",
      "Dkt. 291",
      "Dkt. 293",
      "DOJ-OGR-00005019"
    ]
  },
  "additional_notes": "The document appears to be a formal letter from a law firm to a judge, discussing a court case involving Ghislaine Maxwell. The document is well-formatted and free of significant damage or redactions."
}