mirror-epstein-docs/results/IMAGES004/DOJ-OGR-00011408.json

{
  "document_metadata": {
    "page_number": "2",
    "document_number": "731-1",
    "date": "07/14/22",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": true
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 731-1 Filed 07/14/22 Page 2 of 14 PANISH SHEA & BOYLE LLP The Honorable Alison J. Nathan December 6, 2021 Page 2 Ms. Maxwell's motion concerns an email AUSA Alison Moe sent her colleagues Lara Pomerantz and Maurene Comey concerning an alleged conversation she had with Mr. Glassman on August 17, 2021. Ms. Maxwell appears to seek to compel Mr. Glassman to essentially corroborate a statement in Ms. Moe's email wherein she states \"He also mentioned that he had told her it would 'help her case'\" In the unusual effort to compel a witness's lawyer to testify against his own client, Ms. Maxwell claims that Mr. Glassman waived the attorney-client privilege. It is axiomatic that Mr. Glassman did not and could not waive the attorney-client privilege - only Jane could do that. To be clear, Jane did not and does not waive the privilege in any way. And Jane does not authorize Mr. Glassman to testify about any of his alleged communications with her. Further, as a California attorney, Mr. Glassman is bound by California Rule of Professional Conduct 1.6. (Rule 1.6 is attached hereto as Exhibit 2). Rule 1.6 prohibits an attorney from disclosing confidential information of the client except in two extremely narrow circumstances. A California attorney may only disclose confidential information if: (1) the client gives informed consent, or (2) the attorney believes disclosure is necessary to prevent the client from committing a crime that will cause death or grave bodily harm. Here, to the extent the \"her\" in Ms. Moe's email refers to Jane, Jane gives no such informed consent. And Mr. Glassman obviously has no reason to believe that disclosing any alleged communication he gave minimum, distasteful and designed to intimidate the witness, and should be discouraged. But procedurally, the appearance date on the subpoena is November 29, 2021 - two days before he was served - making it impossible for him to comply. Additionally, Mr. Glassman was not provided with a witness fee or milage fee as required by Rule 17. DOJ-OGR-00011408",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 731-1 Filed 07/14/22 Page 2 of 14",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "The Honorable Alison J. Nathan December 6, 2021 Page 2",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Ms. Maxwell's motion concerns an email AUSA Alison Moe sent her colleagues Lara Pomerantz and Maurene Comey concerning an alleged conversation she had with Mr. Glassman on August 17, 2021. Ms. Maxwell appears to seek to compel Mr. Glassman to essentially corroborate a statement in Ms. Moe's email wherein she states \"He also mentioned that he had told her it would 'help her case'\"",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "In the unusual effort to compel a witness's lawyer to testify against his own client, Ms. Maxwell claims that Mr. Glassman waived the attorney-client privilege. It is axiomatic that Mr. Glassman did not and could not waive the attorney-client privilege - only Jane could do that. To be clear, Jane did not and does not waive the privilege in any way. And Jane does not authorize Mr. Glassman to testify about any of his alleged communications with her.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Further, as a California attorney, Mr. Glassman is bound by California Rule of Professional Conduct 1.6. (Rule 1.6 is attached hereto as Exhibit 2). Rule 1.6 prohibits an attorney from disclosing confidential information of the client except in two extremely narrow circumstances. A California attorney may only disclose confidential information if: (1) the client gives informed consent, or (2) the attorney believes disclosure is necessary to prevent the client from committing a crime that will cause death or grave bodily harm. Here, to the extent the \"her\" in Ms. Moe's email refers to Jane, Jane gives no such informed consent. And Mr. Glassman obviously has no reason to believe that disclosing any alleged communication he gave",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "minimum, distasteful and designed to intimidate the witness, and should be discouraged. But procedurally, the appearance date on the subpoena is November 29, 2021 - two days before he was served - making it impossible for him to comply. Additionally, Mr. Glassman was not provided with a witness fee or milage fee as required by Rule 17.",
      "position": "body"
    },
    {
      "type": "stamp",
      "content": "PANISH SHEA & BOYLE LLP",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00011408",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Alison Moe",
      "Lara Pomerantz",
      "Maurene Comey",
      "Mr. Glassman",
      "Ms. Maxwell",
      "Jane"
    ],
    "organizations": [
      "PANISH SHEA & BOYLE LLP"
    ],
    "locations": [
      "California"
    ],
    "dates": [
      "December 6, 2021",
      "August 17, 2021",
      "November 29, 2021",
      "07/14/22"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "731-1",
      "DOJ-OGR-00011408"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is mostly printed, with a stamp in the top-right corner. There are no visible redactions or damage."
}