mirror-epstein-docs/results/IMAGES002/DOJ-OGR-00003550.json

{
  "document_metadata": {
    "page_number": "1 of 6",
    "document_number": "204-9",
    "date": "04/16/21",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 204-9 Filed 04/16/21 Page 1 of 6 U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 February 28, 2019 TO BE FILED UNDER SEAL VIA EMAIL The Honorable Sarah Netburn United States District Court Southern District of New York United States Courthouse New York, New York 10007 Re: In re Application to Unseal Civil Discovery Materials, USAO No. 2018R01618 Dear Judge Netburn: The Government writes respectfully in connection with its sealed application and proposed order pursuant to the All Writs Act, Title 28, United States Code, Section 1651, for a limited order to unseal discovery materials in the possession of Boies Schiller & Flexner LLP (the \"Application\"), in connection with the matter Jane Doe 43 v. Epstein, et al. (\"Jane Doe\"), 17 Civ. 616 (JGK) (SN) (the \"Litigation\"), a copy of which is attached hereto as Exhibit A. Background As described in the Application, the Government has served a grand jury subpoena (the \"Subpoena\") upon Boies Schiller & Flexner (\"Boies Schiller\") requiring the production of copies of discovery and related materials related to the Litigation. The Subpoena was validly issued pursuant to an ongoing investigation into Jeffrey Epstein and others, for possible violations of Title 18, United States Code, Sections 1591 and 1594(c) (unlawfully trafficking minors) and Section 2422(b) (unlawfully enticing minors) (the \"Investigation\"). The production of materials pursuant to the Subpoena is solely for the purposes of the Investigation, and is subject to the protections and restrictions of Fed. R. Crim. P. 6(e). The Government has been advised that Boies Schiller, which is counsel for plaintiffs in the Litigation, does not intend to contest the Subpoena. However, the Government is advised that although Boies Schiller would not otherwise contest compliance with the Subpoena, it believes that a protective order entered in the Litigation (the \"Protective Order\") may preclude compliance. Accordingly, the Government respectfully requested that the Court issue an order permitting Boies Schiller to comply with the validly-issued Subpoena. CONFIDENTIAL SDNY_GM_00000919 DOJ-OGR-00003550",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 204-9 Filed 04/16/21 Page 1 of 6",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 February 28, 2019",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "TO BE FILED UNDER SEAL",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "VIA EMAIL The Honorable Sarah Netburn United States District Court Southern District of New York United States Courthouse New York, New York 10007",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Re: In re Application to Unseal Civil Discovery Materials, USAO No. 2018R01618 Dear Judge Netburn:",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The Government writes respectfully in connection with its sealed application and proposed order pursuant to the All Writs Act, Title 28, United States Code, Section 1651, for a limited order to unseal discovery materials in the possession of Boies Schiller & Flexner LLP (the \"Application\"), in connection with the matter Jane Doe 43 v. Epstein, et al. (\"Jane Doe\"), 17 Civ. 616 (JGK) (SN) (the \"Litigation\"), a copy of which is attached hereto as Exhibit A.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Background As described in the Application, the Government has served a grand jury subpoena (the \"Subpoena\") upon Boies Schiller & Flexner (\"Boies Schiller\") requiring the production of copies of discovery and related materials related to the Litigation. The Subpoena was validly issued pursuant to an ongoing investigation into Jeffrey Epstein and others, for possible violations of Title 18, United States Code, Sections 1591 and 1594(c) (unlawfully trafficking minors) and Section 2422(b) (unlawfully enticing minors) (the \"Investigation\"). The production of materials pursuant to the Subpoena is solely for the purposes of the Investigation, and is subject to the protections and restrictions of Fed. R. Crim. P. 6(e).",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The Government has been advised that Boies Schiller, which is counsel for plaintiffs in the Litigation, does not intend to contest the Subpoena. However, the Government is advised that although Boies Schiller would not otherwise contest compliance with the Subpoena, it believes that a protective order entered in the Litigation (the \"Protective Order\") may preclude compliance.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Accordingly, the Government respectfully requested that the Court issue an order permitting Boies Schiller to comply with the validly-issued Subpoena.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "CONFIDENTIAL SDNY_GM_00000919 DOJ-OGR-00003550",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Sarah Netburn",
      "Jeffrey Epstein"
    ],
    "organizations": [
      "U.S. Department of Justice",
      "United States Attorney",
      "Boies Schiller & Flexner LLP"
    ],
    "locations": [
      "New York"
    ],
    "dates": [
      "February 28, 2019",
      "04/16/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "204-9",
      "2018R01618",
      "17 Civ. 616 (JGK) (SN)",
      "SDNY_GM_00000919",
      "DOJ-OGR-00003550"
    ]
  },
  "additional_notes": "The document is marked 'CONFIDENTIAL' and 'TO BE FILED UNDER SEAL'. It appears to be a formal letter from the U.S. Department of Justice to a judge regarding a legal matter involving Jeffrey Epstein."
}