{
  "document_metadata": {
    "page_number": "1",
    "document_number": "406",
    "date": "November 2, 2021",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 406 Filed 11/02/21 Page 1 of 6\nU.S Department of Justice\nUnited States Attorney\nSouthern District of New York\nThe Silvio J. Mollo Building\nOne Saint Andrew's Plaza\nNew York, New York 10007\nNovember 2, 2021\nBY ECF\nThe Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\nUnited States Courthouse\n40 Foley Square\nNew York, New York 10007\nRe: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)\nDear Judge Nathan:\nPursuant to the Court's order dated October 31, 2021, the parties write regarding the date for the hearing on the defendant's Rule 412 motion and the defendant's motion to exclude the testimony of Dr. Lisa Rocchio pursuant to Federal Rule of Evidence 702 and Daubert v. Merrell Down Pharmaceuticals, Inc., 509 U.S. 579 (1993).\nGovernment's Position\nLast night, defense counsel emailed the Government expert notice for eight individuals. See Ex. A.1 One of the individuals, Dr. Park Dietz, appears to offer opinions in direct response to Dr. Rocchio's, and another, Dr. Elizabeth Loftus, appears to offer opinions that relate to Dr. Rocchio's.\n1 The Government is submitting Exhibit A temporarily under seal with proposed redactions to give the defense an opportunity to seek any additional redactions. The Government's proposed redactions are consistent with the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Although this letter and its attached exhibit are judicial documents subject to the common law presumption of access, the proposed redactions are narrowly tailored to protect the privacy interests of victims (including victims who have not identified themselves on the record in this case and who have not publicly identified themselves as victims referenced in the Indictment in this case.\nDOJ-OGR-00006043",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 406 Filed 11/02/21 Page 1 of 6",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "U.S Department of Justice\nUnited States Attorney\nSouthern District of New York\nThe Silvio J. Mollo Building\nOne Saint Andrew's Plaza\nNew York, New York 10007",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "November 2, 2021",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "BY ECF\nThe Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\nUnited States Courthouse\n40 Foley Square\nNew York, New York 10007",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Dear Judge Nathan:\nPursuant to the Court's order dated October 31, 2021, the parties write regarding the date for the hearing on the defendant's Rule 412 motion and the defendant's motion to exclude the testimony of Dr. Lisa Rocchio pursuant to Federal Rule of Evidence 702 and Daubert v. Merrell Down Pharmaceuticals, Inc., 509 U.S. 579 (1993).",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Government's Position\nLast night, defense counsel emailed the Government expert notice for eight individuals. See Ex. A.1 One of the individuals, Dr. Park Dietz, appears to offer opinions in direct response to Dr. Rocchio's, and another, Dr. Elizabeth Loftus, appears to offer opinions that relate to Dr. Rocchio's.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "1 The Government is submitting Exhibit A temporarily under seal with proposed redactions to give the defense an opportunity to seek any additional redactions. The Government's proposed redactions are consistent with the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Although this letter and its attached exhibit are judicial documents subject to the common law presumption of access, the proposed redactions are narrowly tailored to protect the privacy interests of victims (including victims who have not identified themselves on the record in this case and who have not publicly identified themselves as victims referenced in the Indictment in this case.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00006043",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ghislaine Maxwell",
      "Lisa Rocchio",
      "Park Dietz",
      "Elizabeth Loftus"
    ],
    "organizations": [
      "U.S Department of Justice",
      "United States Attorney",
      "United States District Court",
      "Southern District of New York"
    ],
    "locations": [
      "New York"
    ],
    "dates": [
      "November 2, 2021",
      "October 31, 2021"
    ],
    "reference_numbers": [
      "20 Cr. 330 (AJN)",
      "509 U.S. 579",
      "435 F.3d 110",
      "DOJ-OGR-00006043"
    ]
  },
  "additional_notes": "The document appears to be a formal letter from the U.S. Department of Justice to the Honorable Alison J. Nathan regarding the case United States v. Ghislaine Maxwell. The letter discusses the defendant's Rule 412 motion and the defendant's motion to exclude the testimony of Dr. Lisa Rocchio. The document is typed and contains no handwritten text or stamps."
}