mirror-epstein-docs/results/IMAGES007/DOJ-OGR-00019571.json

{
  "document_metadata": {
    "page_number": "1",
    "document_number": "120366003830-Adt. Doc.0812412530-Filing808908P20ePage01of03",
    "date": "August 24, 2020",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Haddon, Morgan and Foreman, P.C.\nJeffrey Pagliuca\n150 East 10th Avenue\nDenver, Colorado 80203\nPH 303.831.7364 FX 303.832.2628\nwww.hmflaw.com\njpagliuca@hmflaw.com\n\nAugust 24, 2020\n\nVIA EMAIL\n\nThe Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\n40 Foley Square\nNew York, NY 10007\n\nRe:    Proposed Redactions to Request to Modify Protective Order (Under Seal)\nUnited States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)\n\nDear Judge Nathan,\n\nIn accordance with this Court's Order of August 18, 2020 (Doc. 44), Ms. Maxwell hereby respectfully submits under seal her proposed redactions to her Request to Modify Protective Order (\"Request\"), filed under seal on August 17, 2020. Ms. Maxwell also has filed her Reply under seal and contemporaneously submits her proposed redactions to that pleading.1\n\nMs. Maxwell has no opposition to keeping under seal, and redacting from her Request and Reply, the contents, description and discussion of the sealed materials themselves; because the government has marked them Confidential, the Protective Order requires as much. See Doc. 36, ¶ 15.\n\nThe government's proposed redactions, however, go further and propose to redact . The government would have this Court redact  on the premise that it would \"risk jeopardizing the government's investigation.\"\n\n1 To the extent this Court believes this letter also should be filed publicly, counsel also has indicated her proposed redactions to this letter.\n\nApp.112\nDOJ-OGR-00019571",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Haddon, Morgan and Foreman, P.C.\nJeffrey Pagliuca\n150 East 10th Avenue\nDenver, Colorado 80203\nPH 303.831.7364 FX 303.832.2628\nwww.hmflaw.com\njpagliuca@hmflaw.com",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "August 24, 2020\n\nVIA EMAIL\n\nThe Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\n40 Foley Square\nNew York, NY 10007\n\nRe:    Proposed Redactions to Request to Modify Protective Order (Under Seal)\nUnited States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)\n\nDear Judge Nathan,",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "In accordance with this Court's Order of August 18, 2020 (Doc. 44), Ms. Maxwell hereby respectfully submits under seal her proposed redactions to her Request to Modify Protective Order (\"Request\"), filed under seal on August 17, 2020. Ms. Maxwell also has filed her Reply under seal and contemporaneously submits her proposed redactions to that pleading.1",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Ms. Maxwell has no opposition to keeping under seal, and redacting from her Request and Reply, the contents, description and discussion of the sealed materials themselves; because the government has marked them Confidential, the Protective Order requires as much. See Doc. 36, ¶ 15.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The government's proposed redactions, however, go further and propose to redact . The government would have this Court redact  on the premise that it would \"risk jeopardizing the government's investigation.\"",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "1 To the extent this Court believes this letter also should be filed publicly, counsel also has indicated her proposed redactions to this letter.",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "App.112\nDOJ-OGR-00019571",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Jeffrey Pagliuca",
      "Alison J. Nathan",
      "Ghislaine Maxwell"
    ],
    "organizations": [
      "Haddon, Morgan and Foreman, P.C.",
      "United States District Court",
      "Southern District of New York"
    ],
    "locations": [
      "Denver",
      "Colorado",
      "New York"
    ],
    "dates": [
      "August 24, 2020",
      "August 18, 2020",
      "August 17, 2020"
    ],
    "reference_numbers": [
      "20 Cr. 330 (AJN)",
      "Doc. 44",
      "Doc. 36",
      "App.112",
      "DOJ-OGR-00019571"
    ]
  },
  "additional_notes": "The document contains redactions and is marked as 'Under Seal'."
}