mirror-epstein-docs/results/IMAGES007/DOJ-OGR-00019498.json

{
  "document_metadata": {
    "page_number": "20",
    "document_number": "Case1:20-cr-03320-AJN Document 292 Filed 08/27/20 Page 20 of 1164",
    "date": "July 27, 2020",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "COHEN & GRESSER LLP\n800 Third Avenue\nNew York, NY 10022\n+1 212 957 7600 phone\nwww.cohengresser.com\n\nMark S. Cohen\n+1 (212) 957-7600\nmcohen@cohengresser.com\n\nChristian R. Everdell\n+1 (212) 957-7600\nceverdell@cohengresser.com\n\nJuly 27, 2020\n\nVIA ECF\n\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\n\nRe: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)\n\nDear Judge Nathan:\n\nOn behalf of our client, Ghislaine Maxwell, we respectfully request that the Court enter a protective order in the form attached hereto as Exhibit A.\n\nThe government has indicated that it requires the entry of a protective order before producing any discovery material to Ms. Maxwell. On July 9, 2020, the government provided defense counsel with an initial draft of a proposed protective order. Since that time, the parties have conferred several times on conference calls and by email, and have been able to reach agreement on almost all of the provisions of the proposed protective order.\n\nTwo key disputes remain, however, which require the Court's guidance. First, the defense believes that potential government witnesses and their counsel should be subject to the same restrictions as the defense concerning appropriate use of the discovery materials—namely, if these individuals are given access to discovery materials during trial preparation, they may not use those materials for any purpose other than preparing for trial in the criminal case, and may not post those materials on the Internet. Second, the defense believes it should not be restricted from publicly disclosing or disseminating the identity of any alleged victims or potential witnesses referenced in the discovery materials who have already identified themselves by speaking on the public record.\n\nAs set forth below, we believe that the proposed protective order contains appropriate restrictions that are no broader than necessary to protect the privacy interests of individuals\n\nApp.039\nDOJ-OGR-00019498",
  "text_blocks": [
    {
      "type": "printed",
      "content": "COHEN & GRESSER LLP\n800 Third Avenue\nNew York, NY 10022\n+1 212 957 7600 phone\nwww.cohengresser.com",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Mark S. Cohen\n+1 (212) 957-7600\nmcohen@cohengresser.com\n\nChristian R. Everdell\n+1 (212) 957-7600\nceverdell@cohengresser.com",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "July 27, 2020",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "VIA 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:\n\nOn behalf of our client, Ghislaine Maxwell, we respectfully request that the Court enter a protective order in the form attached hereto as Exhibit A.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The government has indicated that it requires the entry of a protective order before producing any discovery material to Ms. Maxwell. On July 9, 2020, the government provided defense counsel with an initial draft of a proposed protective order. Since that time, the parties have conferred several times on conference calls and by email, and have been able to reach agreement on almost all of the provisions of the proposed protective order.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Two key disputes remain, however, which require the Court's guidance. First, the defense believes that potential government witnesses and their counsel should be subject to the same restrictions as the defense concerning appropriate use of the discovery materials—namely, if these individuals are given access to discovery materials during trial preparation, they may not use those materials for any purpose other than preparing for trial in the criminal case, and may not post those materials on the Internet. Second, the defense believes it should not be restricted from publicly disclosing or disseminating the identity of any alleged victims or potential witnesses referenced in the discovery materials who have already identified themselves by speaking on the public record.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "As set forth below, we believe that the proposed protective order contains appropriate restrictions that are no broader than necessary to protect the privacy interests of individuals",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "App.039\nDOJ-OGR-00019498",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Mark S. Cohen",
      "Christian R. Everdell",
      "Alison J. Nathan",
      "Ghislaine Maxwell"
    ],
    "organizations": [
      "COHEN & GRESSER LLP",
      "United States District Court",
      "Southern District of New York"
    ],
    "locations": [
      "New York",
      "United States"
    ],
    "dates": [
      "July 27, 2020",
      "July 9, 2020"
    ],
    "reference_numbers": [
      "20 Cr. 330 (AJN)",
      "App.039",
      "DOJ-OGR-00019498"
    ]
  },
  "additional_notes": "The document appears to be a formal letter from COHEN & GRESSER LLP to the Honorable Alison J. Nathan regarding the case United States v. Ghislaine Maxwell. The letter discusses the proposed protective order and the disputes between the parties."
}