{
  "document_metadata": {
    "page_number": "1",
    "document_number": "519",
    "date": "November 30, 2021",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 519 Filed 11/30/21 Page 1 of 3\nHaddon, Morgan and Foreman, P.C\nJeffrey S. Pagliuca\n150 East 10th Avenue\nDenver, Colorado 80203\nPH 303.831.7364\nFX 303.832.2628\nwww.hmflaw.com\njpagliuca@hmflaw.com\nNovember 30, 2021\nVIA ECF\nThe Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\n40 Foley Square\nNew York, NY 10007\nRe: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)\nDear Judge Nathan,\nI write following our conferral with the government about protecting the anonymity of certain testifying witnesses in this case. The government suggested to us that we must avoid any public mention of: (1) names of people, places, or specific addresses or locations; (2) particular dates of career events or life events; (3) names of any employers, particular performances, or characters played; (4) specific details of story arcs in any performances played; (5) references to publicly available information or publicly available records that contain a pseudonymous witness's real name; and (6) court filings or other court documents.\nRespectfully, the government's proposal is overly broad and unworkable.\nWe are mindful of the Court's orders on this topic, and we have no objection to many of the government's suggestions—e.g., the names of people or specific addresses or particular employers. But the government's proposal reaches much too far, and it would unfairly constrain Ms. Maxwell's ability to meaningfully and effectively confront her accusers. U.S. Const. amend. VI.\nDOJ-OGR-00008202",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 519 Filed 11/30/21 Page 1 of 3",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Haddon, Morgan and Foreman, P.C\nJeffrey S. Pagliuca\n150 East 10th Avenue\nDenver, Colorado 80203\nPH 303.831.7364\nFX 303.832.2628\nwww.hmflaw.com\njpagliuca@hmflaw.com",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "November 30, 2021\nVIA ECF\nThe Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\n40 Foley Square\nNew York, NY 10007\nRe: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)\nDear Judge Nathan,",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "I write following our conferral with the government about protecting the anonymity of certain testifying witnesses in this case. The government suggested to us that we must avoid any public mention of: (1) names of people, places, or specific addresses or locations; (2) particular dates of career events or life events; (3) names of any employers, particular performances, or characters played; (4) specific details of story arcs in any performances played; (5) references to publicly available information or publicly available records that contain a pseudonymous witness's real name; and (6) court filings or other court documents.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Respectfully, the government's proposal is overly broad and unworkable.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "We are mindful of the Court's orders on this topic, and we have no objection to many of the government's suggestions—e.g., the names of people or specific addresses or particular employers. But the government's proposal reaches much too far, and it would unfairly constrain Ms. Maxwell's ability to meaningfully and effectively confront her accusers. U.S. Const. amend. VI.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00008202",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Jeffrey S. Pagliuca",
      "Alison J. Nathan",
      "Ghislaine Maxwell"
    ],
    "organizations": [
      "Haddon, Morgan and Foreman, P.C",
      "United States District Court",
      "Southern District of New York"
    ],
    "locations": [
      "Denver",
      "Colorado",
      "New York"
    ],
    "dates": [
      "November 30, 2021"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 519",
      "20 Cr. 330 (AJN)",
      "DOJ-OGR-00008202"
    ]
  },
  "additional_notes": "The document appears to be a formal letter from a law firm to a judge regarding a court case. The text is typed, and there are no visible handwritten notes or stamps."
}