mirror-epstein-docs/results/IMAGES007/DOJ-OGR-00019387.json

{
  "document_metadata": {
    "page_number": "21",
    "document_number": "38",
    "date": "09/16/2020",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 20-3061, Document 38, 09/16/2020, 2932233, Page21 of 23\n\nany legal objections to the Government's evidence before Judge Nathan, who is presiding over the criminal case. If Maxwell is dissatisfied with Judge Nathan's rulings on those matters, she will have a full opportunity to appeal those rulings after entry of final judgment in her criminal case. The Court should not permit Maxwell to raise these issues at this juncture, before they have been fully litigated before and adjudicated by the presiding district judge.\n\n28. Moreover, Maxwell's motion to consolidate is a transparent attempt to circumvent Judge Nathan's Order without litigating the merits of this appeal. That Order, which is the only ruling on appeal in this case, prohibits Maxwell from using certain criminal discovery materials in civil litigation. If this Court were to consolidate the criminal and civil appeals, the record on appeal in both cases would be merged, the lines between the two cases would be blurred in the manner Maxwell seeks, and the Court would effectively reverse Judge Nathan's Order and grant Maxwell the relief she seeks in this appeal — all without requiring Maxwell to show that Judge Nathan actually abused her discretion by denying Maxwell's motion to modify the Protective Order.2 Indeed, Maxwell's motion to consolidate does not in any way suggest that there will be anything left\n\n2Moreover, if the appeals were consolidated, the sealed filings in this criminal appeal would become part of the record in the civil appeal. The Government is concerned that consolidating these matters would entail disseminating sensitive, sealed documents in a criminal case to civil litigants.\n\n21\nDOJ-OGR-00019387",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 20-3061, Document 38, 09/16/2020, 2932233, Page21 of 23",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "any legal objections to the Government's evidence before Judge Nathan, who is presiding over the criminal case. If Maxwell is dissatisfied with Judge Nathan's rulings on those matters, she will have a full opportunity to appeal those rulings after entry of final judgment in her criminal case. The Court should not permit Maxwell to raise these issues at this juncture, before they have been fully litigated before and adjudicated by the presiding district judge.",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "28. Moreover, Maxwell's motion to consolidate is a transparent attempt to circumvent Judge Nathan's Order without litigating the merits of this appeal. That Order, which is the only ruling on appeal in this case, prohibits Maxwell from using certain criminal discovery materials in civil litigation. If this Court were to consolidate the criminal and civil appeals, the record on appeal in both cases would be merged, the lines between the two cases would be blurred in the manner Maxwell seeks, and the Court would effectively reverse Judge Nathan's Order and grant Maxwell the relief she seeks in this appeal — all without requiring Maxwell to show that Judge Nathan actually abused her discretion by denying Maxwell's motion to modify the Protective Order.2 Indeed, Maxwell's motion to consolidate does not in any way suggest that there will be anything left",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "2Moreover, if the appeals were consolidated, the sealed filings in this criminal appeal would become part of the record in the civil appeal. The Government is concerned that consolidating these matters would entail disseminating sensitive, sealed documents in a criminal case to civil litigants.",
      "position": "footnote"
    },
    {
      "type": "printed",
      "content": "21",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00019387",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Maxwell",
      "Judge Nathan"
    ],
    "organizations": [
      "Government",
      "Court"
    ],
    "locations": [],
    "dates": [
      "09/16/2020"
    ],
    "reference_numbers": [
      "20-3061",
      "38",
      "2932233",
      "DOJ-OGR-00019387"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a case involving Maxwell. The text discusses legal objections, appeals, and the consolidation of criminal and civil cases. The document is well-formatted and free of significant damage or redactions."
}