mirror-epstein-docs/results/IMAGES007/DOJ-OGR-00019663.json

{
  "document_metadata": {
    "page_number": "17",
    "document_number": "94",
    "date": "10/08/2020",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 20-3061, Document 94, 10/08/2020, 2948481, Page17 of 23\n\nnothing prohibited from informing Judge Preska and Ms. Maxwell about the subpoena; Rule 6(e) does not apply to grand jury witnesses. United States v. Sells Eng'g, Inc., 463 U.S. 418, 425 (1983).\n\nDespite the government's attempt (once again) to mischaracterize Ms. Maxwell's argument,6 this Court need not in this case wade into the propriety of the government's conduct. All Ms. Maxwell seeks is the preservation of her ability to challenge the government's conduct before Judge Nathan. This Court should permit Ms. Maxwell a fair opportunity to persuade Judge Preska and the panel of this Court reviewing her order that the status quo should be preserved.\n\nThe government again implies that because Ms. Maxwell consented to the protective order she can't now complain that it should be modified. Ans.Br. 23-24.7 The government points out that, at the time of her consent, Ms. Maxwell knew\n\n6 The government says that Ms. Maxwell's brief \"appears to be a thinly veiled attempt to have this Court weigh in on the Government's investigative methods.\" Ans.Br. 26. That is not so. All Ms. Maxwell seeks is the ability to fairly challenge before Judge Nathan the government's \"investigative methods.\" As the government does not dispute, that challenge will be compromised unless the deposition material remains sealed. But Judge Preska and the panel of this Court reviewing Judge Preska don't know that, and the government wants to keep it that way.\n\n7 Moreover, the purpose of the criminal protective order's prohibition on using criminal discovery in a civil case is to prevent the introduction of new information in a civil case to gain an advantage. Ms. Maxwell's requested —footnote cont'd on next page—\n\n14\nDOJ-OGR-00019663",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 20-3061, Document 94, 10/08/2020, 2948481, Page17 of 23",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "nothing prohibited from informing Judge Preska and Ms. Maxwell about the subpoena; Rule 6(e) does not apply to grand jury witnesses. United States v. Sells Eng'g, Inc., 463 U.S. 418, 425 (1983).",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Despite the government's attempt (once again) to mischaracterize Ms. Maxwell's argument,6 this Court need not in this case wade into the propriety of the government's conduct. All Ms. Maxwell seeks is the preservation of her ability to challenge the government's conduct before Judge Nathan. This Court should permit Ms. Maxwell a fair opportunity to persuade Judge Preska and the panel of this Court reviewing her order that the status quo should be preserved.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The government again implies that because Ms. Maxwell consented to the protective order she can't now complain that it should be modified. Ans.Br. 23-24.7 The government points out that, at the time of her consent, Ms. Maxwell knew",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "6 The government says that Ms. Maxwell's brief \"appears to be a thinly veiled attempt to have this Court weigh in on the Government's investigative methods.\" Ans.Br. 26. That is not so. All Ms. Maxwell seeks is the ability to fairly challenge before Judge Nathan the government's \"investigative methods.\" As the government does not dispute, that challenge will be compromised unless the deposition material remains sealed. But Judge Preska and the panel of this Court reviewing Judge Preska don't know that, and the government wants to keep it that way.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "7 Moreover, the purpose of the criminal protective order's prohibition on using criminal discovery in a civil case is to prevent the introduction of new information in a civil case to gain an advantage. Ms. Maxwell's requested —footnote cont'd on next page—",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "14",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00019663",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Judge Preska",
      "Ms. Maxwell",
      "Judge Nathan"
    ],
    "organizations": [
      "United States"
    ],
    "locations": [],
    "dates": [
      "10/08/2020"
    ],
    "reference_numbers": [
      "Case 20-3061",
      "Document 94",
      "2948481",
      "DOJ-OGR-00019663"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a case involving Ms. Maxwell. The text is mostly printed, with some footnotes and a header/footer. There are no visible stamps or handwritten text."
}