mirror-epstein-docs/results/IMAGES007/DOJ-OGR-00019554.json

{
  "document_metadata": {
    "page_number": "20",
    "document_number": "272",
    "date": "August 21, 2020",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": true
  },
  "full_text": "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\nAugust 21, 2020\nTO BE FILED PARTIALLY UNDER SEAL\nBY ECF & ELECTRONIC MAIL\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 submits this letter to propose certain redactions to the defendant's letter of August 17, 2020 (the \"Defense Letter\") and to request that the exhibits attached to the Defense Letter be filed under seal during the pendency of an ongoing grand jury investigation. For the reasons set forth below, the Government respectfully requests that the Court permit the filing of the Defense Letter with the proposed redactions contained in Exhibit A hereto (which itself will be submitted to the Court under seal), and that the Court permit all of the exhibits to the Defense Letter to be filed under seal. The Government does not object to the public filing of the affidavit attached to the Defense Letter in unredacted form. Additionally, the Government will file a redacted version of this letter on the public docket, and separately will submit an unredacted version to the Court.\nAs an initial matter, the proposed redactions, and the request that the exhibits be filed under seal, are consistent with the Government's designation of the underlying material as \"Confidential\" within the meaning of the Protective Order in this case. See Protective Order ¶ 15 (Dkt. 36). Moreover, as detailed more fully in the Government's companion submission, that designation is appropriate given the nature of the documents at issue, all of which pertain to the Government's pending grand jury investigation.1 That alone strongly weighs in favor of permitting the redactions and sealed filings at issue: Federal Rule of Criminal Procedure 6(e)(6) provides, in relevant part,\n1 To the extent it would be useful to this Court for the Government to further elaborate on the nature of the ongoing grand jury investigation, the Government is prepared to file a supplemental letter specifically on that subject ex parte and under seal should the Court request such an explanation.\nApp.095\nDOJ-OGR-00019554",
  "text_blocks": [
    {
      "type": "printed",
      "content": "U.S. Department of Justice\nUnited States Attorney\nSouthern District of New York",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "The Silvio J. Mollo Building\nOne Saint Andrew's Plaza\nNew York, New York 10007",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "August 21, 2020",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "TO BE FILED PARTIALLY UNDER SEAL\nBY ECF & ELECTRONIC MAIL",
      "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": "middle"
    },
    {
      "type": "printed",
      "content": "Re:    United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Dear Judge Nathan:",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The Government respectfully submits this letter to propose certain redactions to the defendant's letter of August 17, 2020 (the \"Defense Letter\") and to request that the exhibits attached to the Defense Letter be filed under seal during the pendency of an ongoing grand jury investigation. For the reasons set forth below, the Government respectfully requests that the Court permit the filing of the Defense Letter with the proposed redactions contained in Exhibit A hereto (which itself will be submitted to the Court under seal), and that the Court permit all of the exhibits to the Defense Letter to be filed under seal. The Government does not object to the public filing of the affidavit attached to the Defense Letter in unredacted form. Additionally, the Government will file a redacted version of this letter on the public docket, and separately will submit an unredacted version to the Court.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "As an initial matter, the proposed redactions, and the request that the exhibits be filed under seal, are consistent with the Government's designation of the underlying material as \"Confidential\" within the meaning of the Protective Order in this case. See Protective Order ¶ 15 (Dkt. 36). Moreover, as detailed more fully in the Government's companion submission, that designation is appropriate given the nature of the documents at issue, all of which pertain to the Government's pending grand jury investigation.1 That alone strongly weighs in favor of permitting the redactions and sealed filings at issue: Federal Rule of Criminal Procedure 6(e)(6) provides, in relevant part,",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "1 To the extent it would be useful to this Court for the Government to further elaborate on the nature of the ongoing grand jury investigation, the Government is prepared to file a supplemental letter specifically on that subject ex parte and under seal should the Court request such an explanation.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "App.095\nDOJ-OGR-00019554",
      "position": "footer"
    },
    {
      "type": "stamp",
      "content": "",
      "position": "header"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ghislaine Maxwell"
    ],
    "organizations": [
      "U.S. Department of Justice",
      "United States District Court",
      "United States Courthouse"
    ],
    "locations": [
      "New York"
    ],
    "dates": [
      "August 21, 2020",
      "August 17, 2020"
    ],
    "reference_numbers": [
      "20 Cr. 330 (AJN)",
      "Dkt. 36",
      "App.095",
      "DOJ-OGR-00019554"
    ]
  },
  "additional_notes": "The document is a letter from the U.S. Department of Justice to the Honorable Alison J. Nathan, United States District Court, regarding the case United States v. Ghislaine Maxwell. The letter proposes redactions to the defendant's letter and requests that certain exhibits be filed under seal. The document contains a stamp in the top-left corner."
}