mirror-epstein-docs/results/IMAGES003/DOJ-OGR-00008893.json

{
  "document_metadata": {
    "page_number": "1",
    "document_number": "594",
    "date": "02/04/22",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 594 Filed 02/04/22 Page 1 of 5\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\nFebruary 4, 2022\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 January 26, 2022, which provided that the Government \"may file on ECF\" a response to the defendant's letter filed on February 1, 2022 in which the defendant argued that her motion for a new trial (the \"Defense Motion\") and its exhibits should be sealed. (Dkt. No. 585). For the reasons discussed herein, the Government respectfully submits that the defendant has not justified her sealing request and, accordingly, the Defense Motion and its exhibits should be publicly docketed.\nIn examining whether there is a common law right of access to documents submitted to a court—and thus whether sealing is permissible—courts undertake a three-part inquiry. Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). First, a court must determine whether the record or document in question is a \"judicial document,\" that is, whether the document is \"relevant to the performance of the judicial function and useful in the judicial process,\" such that a presumption of access attaches. Id. at 119 (quoting United States v. Amodeo, 44 F.3d 141, 145 (2d Cir. 1995)). Second, if a document is indeed a \"judicial document,\" the court must determine the weight to be accorded the presumption of access. Lugosch, 435 F.3d at 119. Finally, after\nDOJ-OGR-00008893",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 594 Filed 02/04/22 Page 1 of 5",
      "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": "February 4, 2022",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "BY 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:",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The Government respectfully submits this letter in response to the Court's Order dated January 26, 2022, which provided that the Government \"may file on ECF\" a response to the defendant's letter filed on February 1, 2022 in which the defendant argued that her motion for a new trial (the \"Defense Motion\") and its exhibits should be sealed. (Dkt. No. 585). For the reasons discussed herein, the Government respectfully submits that the defendant has not justified her sealing request and, accordingly, the Defense Motion and its exhibits should be publicly docketed.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "In examining whether there is a common law right of access to documents submitted to a court—and thus whether sealing is permissible—courts undertake a three-part inquiry. Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). First, a court must determine whether the record or document in question is a \"judicial document,\" that is, whether the document is \"relevant to the performance of the judicial function and useful in the judicial process,\" such that a presumption of access attaches. Id. at 119 (quoting United States v. Amodeo, 44 F.3d 141, 145 (2d Cir. 1995)). Second, if a document is indeed a \"judicial document,\" the court must determine the weight to be accorded the presumption of access. Lugosch, 435 F.3d at 119. Finally, after",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00008893",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ghislaine Maxwell"
    ],
    "organizations": [
      "U.S. Department of Justice",
      "United States Attorney",
      "United States District Court",
      "Southern District of New York"
    ],
    "locations": [
      "New York"
    ],
    "dates": [
      "February 4, 2022",
      "January 26, 2022",
      "February 1, 2022"
    ],
    "reference_numbers": [
      "20 Cr. 330 (AJN)",
      "Dkt. No. 585",
      "DOJ-OGR-00008893"
    ]
  },
  "additional_notes": "The document appears to be a formal letter from the U.S. Department of Justice to the Honorable Alison J. Nathan, regarding the case United States v. Ghislaine Maxwell. The letter discusses the defendant's motion for a new trial and the government's response to the court's order. The document is well-formatted and free of significant damage or redactions."
}