mirror-epstein-docs/results/IMAGES002/DOJ-OGR-00005027.json

{
  "document_metadata": {
    "page_number": "1",
    "document_number": "33332",
    "date": "September 1, 2021",
    "document_type": "Court Document",
    "has_handwriting": true,
    "has_stamps": false
  },
  "full_text": "Case#: 2020cr00308P AEJN Document#: 33332 Filed: 09/03/21 Page#: 1 of 3\nU.S Department of Justice\nUnited States Attorney\nSouthern District of New York\nThe Silvio J. Mollo Building\nOne Saint Andrew's Plaza\nNew York, New York 10007\nUSDC SDNY\nDOCUMENT\nELECTRONICALLY FILED\nDOC #:\nDATE FILED: 9/3/21\nBY ECF\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\nRe: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)\nDear Judge Nathan:\nThe Government respectfully submits this letter in response to the Court's Order dated August 23, 2021, which directed the Government to propose and justify any requests for redaction of the Court's temporarily sealed August 13, 2021 Opinion and Order and the underlying motion papers. (Dkt. No. 325). After reviewing the Court's August 13 Opinion and Order, the Government agrees with the defense that no redactions are necessary to that document and accordingly has no objection to the public filing of that document in its entirety.\nAfter reviewing the underlying motion papers, the Government respectfully submits that portions of those papers should be redacted. With respect to Ms. Maxwell's Second Ex Parte and In Camera Motion for an Order Authorizing a Subpoena Pursuant to Fed. R. Crim. P. 17(c)(3) (the \"Motion\"), the Government respectfully submits that limited redactions are appropriate to protect the privacy interests of victims who have not identified themselves on the record in this case and the privacy interests of third parties referenced in the Motion. With respect to Exhibit 1 to the Motion, the Government respectfully submits that the journal entries and photographs contained in Exhibits A, B, and C to Exhibit 1 should be redacted in their entirety to protect the privacy\nSeptember 1, 2021\nThe Court has reviewed the proposed redactions and finds that they are narrowly tailored and necessary to protect the privacy and identities of third parties not identified on the record in this case. The intended recipients of the subpoenas did not file proposed redactions by September 1, 2021, per this Court's August 23 Order. Dkt. No. 325. The Court accordingly ORDERS Defendant to file the redacted Motion and Exhibits 1, 3, and 4, and unredacted Exhibit 2, by September 7, 2021. The Court hereby unseals the August 13 Opinion, and the Court will file the Opinion on the public docket. SO ORDERED.\nAlison J. Nathan\n9/2/21\nDOJ-OGR-00005027",
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      "content": "Case#: 2020cr00308P AEJN Document#: 33332 Filed: 09/03/21 Page#: 1 of 3",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "U.S Department of Justice\nUnited States Attorney\nSouthern District of New York\nThe Silvio J. Mollo Building\nOne Saint Andrew's Plaza\nNew York, New York 10007",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "USDC SDNY\nDOCUMENT\nELECTRONICALLY FILED\nDOC #:\nDATE FILED: 9/3/21",
      "position": "left margin"
    },
    {
      "type": "printed",
      "content": "BY ECF\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",
      "position": "left margin"
    },
    {
      "type": "printed",
      "content": "Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Dear Judge Nathan:",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "The Government respectfully submits this letter in response to the Court's Order dated August 23, 2021, which directed the Government to propose and justify any requests for redaction of the Court's temporarily sealed August 13, 2021 Opinion and Order and the underlying motion papers. (Dkt. No. 325). After reviewing the Court's August 13 Opinion and Order, the Government agrees with the defense that no redactions are necessary to that document and accordingly has no objection to the public filing of that document in its entirety.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "After reviewing the underlying motion papers, the Government respectfully submits that portions of those papers should be redacted. With respect to Ms. Maxwell's Second Ex Parte and In Camera Motion for an Order Authorizing a Subpoena Pursuant to Fed. R. Crim. P. 17(c)(3) (the \"Motion\"), the Government respectfully submits that limited redactions are appropriate to protect the privacy interests of victims who have not identified themselves on the record in this case and the privacy interests of third parties referenced in the Motion. With respect to Exhibit 1 to the Motion, the Government respectfully submits that the journal entries and photographs contained in Exhibits A, B, and C to Exhibit 1 should be redacted in their entirety to protect the privacy",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "September 1, 2021\nThe Court has reviewed the proposed redactions and finds that they are narrowly tailored and necessary to protect the privacy and identities of third parties not identified on the record in this case. The intended recipients of the subpoenas did not file proposed redactions by September 1, 2021, per this Court's August 23 Order. Dkt. No. 325. The Court accordingly ORDERS Defendant to file the redacted Motion and Exhibits 1, 3, and 4, and unredacted Exhibit 2, by September 7, 2021. The Court hereby unseals the August 13 Opinion, and the Court will file the Opinion on the public docket. SO ORDERED.",
      "position": "body"
    },
    {
      "type": "handwritten",
      "content": "Alison J. Nathan\n9/2/21",
      "position": "signature block"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00005027",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ghislaine Maxwell"
    ],
    "organizations": [
      "U.S Department of Justice",
      "United States Attorney",
      "United States District Court"
    ],
    "locations": [
      "New York"
    ],
    "dates": [
      "September 1, 2021",
      "August 23, 2021",
      "August 13, 2021",
      "September 7, 2021",
      "9/3/21",
      "9/2/21"
    ],
    "reference_numbers": [
      "20 Cr. 330 (AJN)",
      "Dkt. No. 325",
      "2020cr00308P AEJN",
      "33332",
      "DOJ-OGR-00005027"
    ]
  },
  "additional_notes": "The document appears to be a court filing in the case United States v. Ghislaine Maxwell. It includes a letter from the Government to Judge Alison J. Nathan regarding proposed redactions to certain documents. The document is signed by Alison J. Nathan on 9/2/21."
}