mirror-epstein-docs/results/IMAGES003/DOJ-OGR-00008040.json

{
  "document_metadata": {
    "page_number": "1",
    "document_number": "506",
    "date": "November 24, 2021",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 506 Filed 11/24/21 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 24, 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. 495, the Government submits proposed redactions to the filings associated with the Government's motion to preclude six defense experts.\nIn addition to the proposed redactions, the Government respectfully seeks to redact Government Exhibit A, the defense expert notice, which the Government has filed on the docket with the same redactions (see Dkt. No. 424-1), and moves to file Government Exhibit B under seal. The Government's proposed redactions and sealing 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).\nAlthough the parties' 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, including a Minor Victim who is a subject of the Court's pseudonym order.\nThe defense has informed the Government that it is not seeking any additional redactions.\nDOJ-OGR-00008040",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 506 Filed 11/24/21 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 24, 2021",
      "position": "header"
    },
    {
      "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": "top"
    },
    {
      "type": "printed",
      "content": "Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Dear Judge Nathan:\nPursuant to the Court's Order at Dkt. No. 495, the Government submits proposed redactions to the filings associated with the Government's motion to preclude six defense experts.\nIn addition to the proposed redactions, the Government respectfully seeks to redact Government Exhibit A, the defense expert notice, which the Government has filed on the docket with the same redactions (see Dkt. No. 424-1), and moves to file Government Exhibit B under seal. The Government's proposed redactions and sealing 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).\nAlthough the parties' 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, including a Minor Victim who is a subject of the Court's pseudonym order.\nThe defense has informed the Government that it is not seeking any additional redactions.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00008040",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ghislaine Maxwell"
    ],
    "organizations": [
      "U.S Department of Justice",
      "United States Attorney",
      "United States District Court",
      "Second Circuit"
    ],
    "locations": [
      "New York",
      "Onondaga"
    ],
    "dates": [
      "November 24, 2021"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 506",
      "20 Cr. 330 (AJN)",
      "Dkt. No. 495",
      "Dkt. No. 424-1",
      "DOJ-OGR-00008040"
    ]
  },
  "additional_notes": "The document appears to be a formal letter from the U.S. Department of Justice to the Honorable Alison J. Nathan regarding the case United States v. Ghislaine Maxwell. The letter discusses proposed redactions to certain filings and the sealing of Government Exhibit B. The document is typed and does not contain any handwritten text or stamps."
}