mirror-epstein-docs/results/IMAGES003/DOJ-OGR-00007464.json

{
  "document_metadata": {
    "page_number": "1",
    "document_number": "498",
    "date": "November 23, 2021",
    "document_type": "Court Document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 498 Filed 11/23/21 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 23, 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. 482, the Government seeks redactions to Exhibit 1 to the defendant's response to the Government's motion to preclude the testimony of Dr. Dietz and Dr. Loftus. 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 the Minor Victims and third parties, including individuals who have not identified themselves on the record in this case, and who are subjects of the Court's pseudonym order.\nThe Government does not seek redactions to the defense response or the Court's Opinion & Order. The defense has informed the Government that it is not seeking any additional redactions.\nDOJ-OGR-00007464",
  "text_blocks": [
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      "content": "Case 1:20-cr-00330-PAE Document 498 Filed 11/23/21 Page 1 of 2",
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    {
      "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 23, 2021",
      "position": "header"
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    {
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      "content": "BY ECF",
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    {
      "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",
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    {
      "type": "printed",
      "content": "Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)",
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    {
      "type": "printed",
      "content": "Dear Judge Nathan:",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Pursuant to the Court's Order at Dkt. No. 482, the Government seeks redactions to Exhibit 1 to the defendant's response to the Government's motion to preclude the testimony of Dr. Dietz and Dr. Loftus. 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 the Minor Victims and third parties, including individuals who have not identified themselves on the record in this case, and who are subjects of the Court's pseudonym order.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The Government does not seek redactions to the defense response or the Court's Opinion & Order. The defense has informed the Government that it is not seeking any additional redactions.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00007464",
      "position": "footer"
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  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ghislaine Maxwell",
      "Dr. Dietz",
      "Dr. Loftus"
    ],
    "organizations": [
      "U.S Department of Justice",
      "United States Attorney",
      "United States District Court",
      "Southern District of New York"
    ],
    "locations": [
      "New York"
    ],
    "dates": [
      "November 23, 2021"
    ],
    "reference_numbers": [
      "20 Cr. 330 (AJN)",
      "Dkt. No. 482",
      "DOJ-OGR-00007464"
    ]
  },
  "additional_notes": "The document appears to be a court filing in the case United States v. Ghislaine Maxwell. The text is well-formatted and clear. There are no visible redactions or damage to the document."
}