{
  "document_metadata": {
    "page_number": "1",
    "document_number": "481",
    "date": "November 21, 2021",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 481 Filed 11/21/21 Page 1 of 2\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 21, 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 at Dkt. No. 477, the Government is submitting today proposed redactions to the parties' supplemental briefing regarding Witness-3 and the Court's Memorandum Opinion & Order resolving those motions.\nThe 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 the parties' supplemental briefing and the Court's Opinion & Order are judicial documents subject to the common law presumption of access, the limited proposed redactions are narrowly tailored to protect the privacy interests of Witness-3, who has not identified herself on the record in this case, and who is a subject of the Court's pseudonym order. In addition, some of the proposed redactions reference sealed materials from the Rule 412 litigation, which are \"related materials\" within the meaning of Fed. R. Evid. 412(c)(2).\nDOJ-OGR-00007383",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 481 Filed 11/21/21 Page 1 of 2",
      "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 21, 2021",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "BY ECF",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The 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 at Dkt. No. 477, the Government is submitting today proposed redactions to the parties' supplemental briefing regarding Witness-3 and the Court's Memorandum Opinion & Order resolving those motions.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "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 the parties' supplemental briefing and the Court's Opinion & Order are judicial documents subject to the common law presumption of access, the limited proposed redactions are narrowly tailored to protect the privacy interests of Witness-3, who has not identified herself on the record in this case, and who is a subject of the Court's pseudonym order. In addition, some of the proposed redactions reference sealed materials from the Rule 412 litigation, which are \"related materials\" within the meaning of Fed. R. Evid. 412(c)(2).",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00007383",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ghislaine Maxwell",
      "Judge Nathan",
      "Witness-3"
    ],
    "organizations": [
      "U.S Department of Justice",
      "United States Attorney",
      "United States District Court",
      "Second Circuit"
    ],
    "locations": [
      "New York",
      "Onondaga"
    ],
    "dates": [
      "November 21, 2021",
      "2006"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 481",
      "20 Cr. 330 (AJN)",
      "Dkt. No. 477",
      "435 F.3d 110",
      "DOJ-OGR-00007383"
    ]
  },
  "additional_notes": "The document appears to be a formal letter from the U.S. Department of Justice to Judge Alison J. Nathan regarding the case United States v. Ghislaine Maxwell. The letter discusses proposed redactions to certain documents and references relevant legal precedents and rules."
}