{ "document_metadata": { "page_number": "6", "document_number": "52", "date": "09/02/20", "document_type": "court document", "has_handwriting": false, "has_stamps": false }, "full_text": "Case 1:20-cr-00330-AJN Document 52 Filed 09/02/20 Page 6 of 8\nThe Honorable Alison J. Nathan\nAugust 17, 2020\nPage 6\nThere are at least three compelling reasons to modify the Protective Order. First, [REDACTED]\nThe partial secrecy surrounding the Material has also fundamentally undermined the fairness of the adversarial process. Although the grand jury subpoena and government investigation were known to [REDACTED]\n\"The rule does not impose any obligation of secrecy on witnesses.\" Fed. R. Crim. P. 6, Advisory Committee Note to Subdivision 6(e)2. [REDACTED]\nToo many questions remain unanswered including exactly what was said between the government and [REDACTED], when was it said, and precisely what was turned over.\nWithout the ability to use the Material in the very limited fashion proposed Ms. Maxwell she is unfairly disadvantaged [REDACTED]\nMoreover, instead of candidly revealing the fact of the subpoena [REDACTED]\nSecond, [REDACTED]\nDOJ-OGR-00001757", "text_blocks": [ { "type": "printed", "content": "Case 1:20-cr-00330-AJN Document 52 Filed 09/02/20 Page 6 of 8", "position": "header" }, { "type": "printed", "content": "The Honorable Alison J. Nathan\nAugust 17, 2020\nPage 6", "position": "header" }, { "type": "printed", "content": "There are at least three compelling reasons to modify the Protective Order. First, [REDACTED]", "position": "body" }, { "type": "printed", "content": "The partial secrecy surrounding the Material has also fundamentally undermined the fairness of the adversarial process. Although the grand jury subpoena and government investigation were known to [REDACTED]", "position": "body" }, { "type": "printed", "content": "\"The rule does not impose any obligation of secrecy on witnesses.\" Fed. R. Crim. P. 6, Advisory Committee Note to Subdivision 6(e)2. [REDACTED]", "position": "body" }, { "type": "printed", "content": "Too many questions remain unanswered including exactly what was said between the government and [REDACTED], when was it said, and precisely what was turned over.", "position": "body" }, { "type": "printed", "content": "Without the ability to use the Material in the very limited fashion proposed Ms. Maxwell she is unfairly disadvantaged [REDACTED]", "position": "body" }, { "type": "printed", "content": "Moreover, instead of candidly revealing the fact of the subpoena [REDACTED]", "position": "body" }, { "type": "printed", "content": "Second, [REDACTED]", "position": "body" }, { "type": "printed", "content": "DOJ-OGR-00001757", "position": "footer" } ], "entities": { "people": [ "Alison J. Nathan", "Ms. Maxwell" ], "organizations": [ "DOJ" ], "locations": [], "dates": [ "August 17, 2020", "09/02/20" ], "reference_numbers": [ "1:20-cr-00330-AJN", "Document 52", "DOJ-OGR-00001757" ] }, "additional_notes": "The document contains redactions, likely due to sensitive information. The text is mostly printed, with no visible handwriting or stamps." }