mirror-epstein-docs/results/IMAGES007/DOJ-OGR-00019617.json

{
  "document_metadata": {
    "page_number": "10",
    "document_number": "82",
    "date": "10/02/2020",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "4\n\nin discovery in the criminal case. (A. 75-86). The Protective Order expressly provides that any and all discovery material produced to Maxwell by the Government, regardless of designation, \"[s]hall be used by the Defendant or her Defense Counsel solely for purposes of the defense of this criminal action, and not for any civil proceeding or any purpose other than the defense of this action.\" (Protective Order ¶¶ 1(a), 10(a), 14(a)). The Protective Order further provides that any discovery material produced to Maxwell by the Government that is marked \"confidential\" may not be filed publicly or excerpted within any public filing. (Protective Order ¶ 15). Maxwell's criminal defense counsel consented to the foregoing provisions of the Protective Order. (See A. 40, 44-55).\n\nC. The District Court Litigation\n\nDespite having agreed to the prohibition on using the discovery materials in civil cases, on August 17, 2020, Maxwell asked Judge Nathan to modify the Protective Order to allow her to do exactly that. (A. 124-31). In particular, Maxwell's motion sought authorization to use materials relating to applications the Government previously made in 2019 seeking the modification of certain protective orders in other judicial proceedings.\n\nOn August 21, 2020, the Government filed an opposition to Maxwell's motion to modify the Protective Order. (A. 90-94). In its opposition, the Government explained the factual background regarding the confidential criminal discovery materials at issue. In par-",
  "text_blocks": [
    {
      "type": "printed",
      "content": "4",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "in discovery in the criminal case. (A. 75-86). The Protective Order expressly provides that any and all discovery material produced to Maxwell by the Government, regardless of designation, \"[s]hall be used by the Defendant or her Defense Counsel solely for purposes of the defense of this criminal action, and not for any civil proceeding or any purpose other than the defense of this action.\" (Protective Order ¶¶ 1(a), 10(a), 14(a)). The Protective Order further provides that any discovery material produced to Maxwell by the Government that is marked \"confidential\" may not be filed publicly or excerpted within any public filing. (Protective Order ¶ 15). Maxwell's criminal defense counsel consented to the foregoing provisions of the Protective Order. (See A. 40, 44-55).",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "C. The District Court Litigation",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Despite having agreed to the prohibition on using the discovery materials in civil cases, on August 17, 2020, Maxwell asked Judge Nathan to modify the Protective Order to allow her to do exactly that. (A. 124-31). In particular, Maxwell's motion sought authorization to use materials relating to applications the Government previously made in 2019 seeking the modification of certain protective orders in other judicial proceedings.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "On August 21, 2020, the Government filed an opposition to Maxwell's motion to modify the Protective Order. (A. 90-94). In its opposition, the Government explained the factual background regarding the confidential criminal discovery materials at issue. In par-",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00019617",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Maxwell",
      "Judge Nathan"
    ],
    "organizations": [
      "Government"
    ],
    "locations": [],
    "dates": [
      "August 17, 2020",
      "August 21, 2020",
      "2019"
    ],
    "reference_numbers": [
      "20-3061",
      "Document 82",
      "2944267",
      "Page 10 of 37",
      "A. 75-86",
      "A. 40, 44-55",
      "A. 124-31",
      "A. 90-94"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Maxwell. The text is mostly printed, with no visible handwriting or stamps. The document is well-formatted and legible."
}