{
  "document_metadata": {
    "page_number": "1",
    "document_number": "544",
    "date": "December 13, 2021",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 544 Filed 12/14/21 Page 1 of 9\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\nDecember 13, 2021\nVIA Email\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 to alert the Court to the questions Ms. Maxwell anticipates asking Attorneys Jack Scarola, Brad Edwards, and Robert Glassman, and to explain why none of the answers they will offer are protected by the attorney client privilege.\n\"The attorney-client privilege protects from disclosure (1) a communication between client and counsel that (2) was intended to be and was in fact kept confidential, and (3) was made for the purpose of obtaining or providing legal advice.\" In re County of Erie, 473 F.3d 413, 419 (2d Cir. 2007). \"The burden of establishing the attorney-client privilege, in all its elements, always rests upon the person asserting it.\" United States v. Schwimmer, 892 F.2d 237, 244 (2d Cir. 1989). The burden here falls on the government.\nNone of the questions Ms. Maxwell intends to ask these witnesses implicates the attorney-client privilege. Indeed, none calls for an attorney to reveal confidential communications with his client at all, let alone a communication made for the purpose of obtaining or providing legal advice. Rather, all the questions concern interactions between the\nDOJ-OGR-00008364",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 544 Filed 12/14/21 Page 1 of 9",
      "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": "December 13, 2021\nVIA Email\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 to alert the Court to the questions Ms. Maxwell anticipates asking Attorneys Jack Scarola, Brad Edwards, and Robert Glassman, and to explain why none of the answers they will offer are protected by the attorney client privilege.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "\"The attorney-client privilege protects from disclosure (1) a communication between client and counsel that (2) was intended to be and was in fact kept confidential, and (3) was made for the purpose of obtaining or providing legal advice.\" In re County of Erie, 473 F.3d 413, 419 (2d Cir. 2007). \"The burden of establishing the attorney-client privilege, in all its elements, always rests upon the person asserting it.\" United States v. Schwimmer, 892 F.2d 237, 244 (2d Cir. 1989). The burden here falls on the government.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "None of the questions Ms. Maxwell intends to ask these witnesses implicates the attorney-client privilege. Indeed, none calls for an attorney to reveal confidential communications with his client at all, let alone a communication made for the purpose of obtaining or providing legal advice. Rather, all the questions concern interactions between the",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00008364",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Jeffrey S. Pagliuca",
      "Alison J. Nathan",
      "Ghislaine Maxwell",
      "Jack Scarola",
      "Brad Edwards",
      "Robert Glassman",
      "Schwimmer"
    ],
    "organizations": [
      "Haddon, Morgan and Foreman, P.C",
      "United States District Court",
      "Southern District of New York"
    ],
    "locations": [
      "Denver",
      "Colorado",
      "New York"
    ],
    "dates": [
      "December 13, 2021",
      "12/14/21"
    ],
    "reference_numbers": [
      "Case 1:20-cr-00330-PAE",
      "Document 544",
      "20 Cr. 330 (AJN)",
      "473 F.3d 413",
      "892 F.2d 237",
      "DOJ-OGR-00008364"
    ]
  },
  "additional_notes": "The document appears to be a letter from Jeffrey S. Pagliuca to Judge Alison J. Nathan regarding the case United States v. Ghislaine Maxwell. The letter discusses the attorney-client privilege and its application to certain questions that Ms. Maxwell intends to ask witnesses."
}