mirror-epstein-docs/results/IMAGES003/DOJ-OGR-00008301.json

{
  "document_metadata": {
    "page_number": "1 of 2",
    "document_number": "534",
    "date": "December 9, 2021",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 534 Filed 12/09/21 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\nDecember 9, 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:\nThe Government respectfully seeks redactions to its letter motion for admission of Government Exhibit 52 (Dkt. No. 533), sealing of Exhibit A to that letter, and redactions to Exhibit B to that letter. 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 Government's letter and exhibits are judicial documents subject to the common law presumption of access, the limited proposed redactions and sealing are narrowly tailored to protect the privacy interests of the Minor Victims and witnesses, including individuals who are subjects of the Court's pseudonym order, as well as third parties. The Government also notes that the redactions to Exhibit B conform to redactions of that document in Giuffre v. Maxwell, 15 Civ. 7433 (LAP).\nDOJ-OGR-00008301",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 534 Filed 12/09/21 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": "December 9, 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:",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The Government respectfully seeks redactions to its letter motion for admission of Government Exhibit 52 (Dkt. No. 533), sealing of Exhibit A to that letter, and redactions to Exhibit B to that letter. 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 Government's letter and exhibits are judicial documents subject to the common law presumption of access, the limited proposed redactions and sealing are narrowly tailored to protect the privacy interests of the Minor Victims and witnesses, including individuals who are subjects of the Court's pseudonym order, as well as third parties. The Government also notes that the redactions to Exhibit B conform to redactions of that document in Giuffre v. Maxwell, 15 Civ. 7433 (LAP).",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00008301",
      "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": [
      "December 9, 2021"
    ],
    "reference_numbers": [
      "20 Cr. 330 (AJN)",
      "15 Civ. 7433 (LAP)",
      "Dkt. No. 533",
      "DOJ-OGR-00008301"
    ]
  },
  "additional_notes": "The document is a 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 exhibits and is typed in a formal font. There are no visible handwritten notes or stamps on the document."
}