95% - getting closeeee

Author: nickp

processing_index.json

@@ -0,0 +1,77 @@
+{
+  "document_metadata": {
+    "page_number": "3",
+    "document_number": "120366006838",
+    "date": "August 24, 2020",
+    "document_type": "Court Document",
+    "has_handwriting": false,
+    "has_stamps": false
+  },
+  "full_text": "Case 120366006838 Document 208 Filed 08/24/20 Page 3 of 5 The Honorable Alison J. Nathan August 24, 2020 Page 3 see also Palmieri v. State of New York, 779 F.2d 861 (2d Cir. 1987); Abbott Laboratories v. Adelphia Supply USA, Case 2015-cv-5826 (CBA) (MDG), 2016 WL 11613256 (S.D.N.Y. Nov. 22, 2016) (“In the Second Circuit, there is a presumption in favor of enforcing protective orders against grand jury subpoenas.”); United States v. Kerik, 07 CR 1027, 2014 WL 12710346 (S.D.N.Y. July 23, 2014). It seems that a majority of courts in this district have rejected the claimed “standard practice” arguments made by the Government __________. A notable difference is that the other applications were not conducted ex parte. ___________ ___________ ___________ ___________ ___________ ___________ Ms. Maxwell is not asking this Court to decide that question today. But Ms. Maxwell is seeking __________ ___________ ___________ ___________ ___________ ___________ ___________ ___________ ___________ ___________ ___________ ___________ ___________ ___________ ___________ ___________ ___________ ___________ ___________ ___________ The Government Does Not Explain How Any “Secret” Investigation Will be Compromised. Third, the government claims that the materials at issue are “Confidential” because the “full scope and details” of their very-public proclamations of an ongoing criminal investigation “have not been made public.” Resp. at 3. This argument too is nonsensical: the sealed materials that Ms. Maxwell seeks to file, under seal, __________ ___________ ___________ ___________ ___________ ___________ ___________ ___________ ___________ ___________ ___________ ___________ ___________ ___________ Certainly the subpoena recipient, otherwise known as counsel for the adverse party to the Civil Litigation, knows the two things that Ms. Maxwell seeks to file under seal in App.117 DOJ-OGR-00019576",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case 120366006838 Document 208 Filed 08/24/20 Page 3 of 5",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "The Honorable Alison J. Nathan August 24, 2020 Page 3",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "see also Palmieri v. State of New York, 779 F.2d 861 (2d Cir. 1987); Abbott Laboratories v. Adelphia Supply USA, Case 2015-cv-5826 (CBA) (MDG), 2016 WL 11613256 (S.D.N.Y. Nov. 22, 2016) (“In the Second Circuit, there is a presumption in favor of enforcing protective orders against grand jury subpoenas.”); United States v. Kerik, 07 CR 1027, 2014 WL 12710346 (S.D.N.Y. July 23, 2014). It seems that a majority of courts in this district have rejected the claimed “standard practice” arguments made by the Government __________. A notable difference is that the other applications were not conducted ex parte.",
+      "position": "body"
+    },
+    {
+      "type": "printed",
+      "content": "Ms. Maxwell is not asking this Court to decide that question today. But Ms. Maxwell is seeking __________ ___________ ___________ ___________ ___________ ___________ ___________ ___________ ___________ ___________ ___________ ___________ ___________ ___________ ___________ ___________ ___________ ___________ ___________ ___________",
+      "position": "body"
+    },
+    {
+      "type": "printed",
+      "content": "The Government Does Not Explain How Any “Secret” Investigation Will be Compromised. Third, the government claims that the materials at issue are “Confidential” because the “full scope and details” of their very-public proclamations of an ongoing criminal investigation “have not been made public.” Resp. at 3. This argument too is nonsensical: the sealed materials that Ms. Maxwell seeks to file, under seal, __________ ___________ ___________ ___________ ___________ ___________ ___________ ___________ ___________ ___________ ___________ ___________ ___________ ___________",
+      "position": "body"
+    },
+    {
+      "type": "printed",
+      "content": "Certainly the subpoena recipient, otherwise known as counsel for the adverse party to the Civil Litigation, knows the two things that Ms. Maxwell seeks to file under seal in",
+      "position": "body"
+    },
+    {
+      "type": "printed",
+      "content": "App.117",
+      "position": "footer"
+    },
+    {
+      "type": "printed",
+      "content": "DOJ-OGR-00019576",
+      "position": "footer"
+    }
+  ],
+  "entities": {
+    "people": [
+      "Alison J. Nathan",
+      "Ms. Maxwell"
+    ],
+    "organizations": [],
+    "locations": [
+      "New York",
+      "S.D.N.Y."
+    ],
+    "dates": [
+      "August 24, 2020",
+      "Nov. 22, 2016",
+      "July 23, 2014"
+    ],
+    "reference_numbers": [
+      "120366006838",
+      "2015-cv-5826",
+      "07 CR 1027",
+      "App.117",
+      "DOJ-OGR-00019576"
+    ]
+  },
+  "additional_notes": "The document contains redactions, indicated by black bars, and appears to be a court filing related to a legal case involving Ms. Maxwell."
+}

results/IMAGES007/DOJ-OGR-00019576.json

@@ -0,0 +1,82 @@
+{
+  "document_metadata": {
+    "page_number": "4",
+    "document_number": "12036600638",
+    "date": "August 24, 2020",
+    "document_type": "Court Document",
+    "has_handwriting": false,
+    "has_stamps": false
+  },
+  "full_text": "Case 12036600638 Doc 81 Filed 08/24/20 Page 4 of 5\nThe Honorable Alison J. Nathan\nAugust 24, 2020\nPage 4\nthat matter: .\n2\nThe government does not explain, because they cannot, how it will harm an ongoing criminal investigation to reveal the sealed materials under seal to two arbiters: . Clearly those judicial officers are fully capable of maintaining files under seal and confidences. Nor is there any support for the argument that this limited request will \"permit dissemination of a vast swath of materials.\" Resp. at 3. The slippery slope contention is belied by the limited nature of Ms. Maxwell's request. The sealed materials are a discrete set of judicial documents, not a \"vast swath of materials,\" and Ms. Maxwell seeks to file them under seal for those Courts to use in their determinations. Hyperbole aside, the request is appropriately limited.\nFurther, the government's suggestion that \"there is no impediment to counsel making sealed applications to Court-1 and Court-2, respectively, to unseal the relevant materials\" is, at best, baffling. Resp. at 3 n.5. Such a \"sealed application\" in furtherance of her Civil Litigation would be \"using\" the materials for the civil case, exactly the conduct proscribed by the Protective Order here. If the Court disagrees, Ms. Maxwell is more than happy to make such sealed applications to those judicial officers. The government does not explain its thinking, nor did the government suggest this course of action during the conferral process.\nThe Sealed Materials Are Important to\nFourth, the government decries the sealed materials' lack of relevance to\n2 Ms. Maxwell strenuously opposes the government's suggestion that it \"further elaborate on the nature of the ongoing grand jury investigation\" in a supplemental ex parte and sealed pleading. This Court is overseeing the criminal case pertaining to Ms. Maxwell and any ex parte pleading concerning this case to this judicial officer is inappropriate. See Standard 3-3.3 Relationship with Courts, Defense Counsel and Others, \"Criminal Justice Standards for the Prosecution Function,\" American Bar Ass'n (4th ed. 2017) (\"A prosecutor should not engage in unauthorized ex parte discussions with, or submission of material to, a judge relating to a particular matter which is, or is likely to be, before the judge.\")\nApp.118\nDOJ-OGR-00019577",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case 12036600638 Doc 81 Filed 08/24/20 Page 4 of 5",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "The Honorable Alison J. Nathan\nAugust 24, 2020\nPage 4",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "that matter: .\n2",
+      "position": "body"
+    },
+    {
+      "type": "printed",
+      "content": "The government does not explain, because they cannot, how it will harm an ongoing criminal investigation to reveal the sealed materials under seal to two arbiters: . Clearly those judicial officers are fully capable of maintaining files under seal and confidences. Nor is there any support for the argument that this limited request will \"permit dissemination of a vast swath of materials.\" Resp. at 3. The slippery slope contention is belied by the limited nature of Ms. Maxwell's request. The sealed materials are a discrete set of judicial documents, not a \"vast swath of materials,\" and Ms. Maxwell seeks to file them under seal for those Courts to use in their determinations. Hyperbole aside, the request is appropriately limited.",
+      "position": "body"
+    },
+    {
+      "type": "printed",
+      "content": "Further, the government's suggestion that \"there is no impediment to counsel making sealed applications to Court-1 and Court-2, respectively, to unseal the relevant materials\" is, at best, baffling. Resp. at 3 n.5. Such a \"sealed application\" in furtherance of her Civil Litigation would be \"using\" the materials for the civil case, exactly the conduct proscribed by the Protective Order here. If the Court disagrees, Ms. Maxwell is more than happy to make such sealed applications to those judicial officers. The government does not explain its thinking, nor did the government suggest this course of action during the conferral process.",
+      "position": "body"
+    },
+    {
+      "type": "printed",
+      "content": "The Sealed Materials Are Important to",
+      "position": "body"
+    },
+    {
+      "type": "printed",
+      "content": "Fourth, the government decries the sealed materials' lack of relevance to",
+      "position": "body"
+    },
+    {
+      "type": "printed",
+      "content": "2 Ms. Maxwell strenuously opposes the government's suggestion that it \"further elaborate on the nature of the ongoing grand jury investigation\" in a supplemental ex parte and sealed pleading. This Court is overseeing the criminal case pertaining to Ms. Maxwell and any ex parte pleading concerning this case to this judicial officer is inappropriate. See Standard 3-3.3 Relationship with Courts, Defense Counsel and Others, \"Criminal Justice Standards for the Prosecution Function,\" American Bar Ass'n (4th ed. 2017) (\"A prosecutor should not engage in unauthorized ex parte discussions with, or submission of material to, a judge relating to a particular matter which is, or is likely to be, before the judge.\")",
+      "position": "footer"
+    },
+    {
+      "type": "printed",
+      "content": "App.118",
+      "position": "footer"
+    },
+    {
+      "type": "printed",
+      "content": "DOJ-OGR-00019577",
+      "position": "footer"
+    }
+  ],
+  "entities": {
+    "people": [
+      "Alison J. Nathan",
+      "Ms. Maxwell"
+    ],
+    "organizations": [
+      "American Bar Ass'n"
+    ],
+    "locations": [],
+    "dates": [
+      "August 24, 2020"
+    ],
+    "reference_numbers": [
+      "12036600638",
+      "DOJ-OGR-00019577",
+      "App.118"
+    ]
+  },
+  "additional_notes": "The document appears to be a court filing with redactions. The text is mostly printed, with some footnotes and citations. The document is related to a court case involving Ms. Maxwell and discusses sealed materials and their relevance to the case."
+}

results/IMAGES007/DOJ-OGR-00019577.json

@@ -0,0 +1,74 @@
+{
+  "document_metadata": {
+    "page_number": "5",
+    "document_number": "120366006380",
+    "date": "August 24, 2020",
+    "document_type": "court document",
+    "has_handwriting": false,
+    "has_stamps": false
+  },
+  "full_text": "The Honorable Alison J. Nathan\nAugust 24, 2020\nPage 5\n\nProtective Orders May Be Modified As Circumstances Change\nFinally, the government suggests in a myriad of ways without directly arguing that this Protective Order cannot be modified, that Ms. Maxwell somehow waived her ability to seek modification by agreeing to a Protective Order before she knew what was contained in the criminal discovery, or that there is no precedent for such a modification. These suggestions are disingenuous. Of course, the Government ignores that the Protective Order itself provides that it may be modified \"by further order of the Court.\" Id., ¶ 18(b).\n\nThere is no precedence for this case. That is true because the Second Circuit has outlined a process for the government to seek civil materials subject to protective orders for use in grand jury investigations, a process the government circumvented. It also is true because typically, the government is the party to intervene in civil cases and seek a stay where materials the government has marked \"Confidential\" may be disclosed publicly or where the government contends the rules of criminal discovery will be circumvented. Finally, there is no other case that defense counsel has located where\n\nThat Ms. Maxwell did not know what was in the sealed materials before she signed the Protective Order, or proposed a draft, is self-evident. That a Court can modify a protective order at any time is likewise well-established. Fed. R. Crim. P. 16(d)(1) authorizes the Court to regulate discovery through protective orders and modification of those orders. See Smith Kline Beecham Corp. v. Synthon Pharmaceuticals, Ltd., 210 F.R.D. 163, 166 (M.D.N.C. 2002) (\"[c]ourts have the inherent power to modify protective orders, including protective orders arising from a stipulation by the parties\"); see also United States v. Gurney, 558 F.2d 1202, 1211 n.15 (5th Cir. 1977) (trial court's decisions as to which documents \"will be placed in the public domain, and which are entitled to privacy and confidentiality\" are discretionary and \"form an integral part of trial management\"); United States v. Wecht, 484 F.3d 194, 211 (3d Cir. 2007), as amended (July 2, 2007) (\"it would have been proper for the District Court to unseal the records pursuant to its general discretionary powers\"); Poliquin v. Garden Way, Inc., 989 F.2d 527, 532 & 535 (1st Cir. 1993).\n\n\"The standard of review for a request to vacate or modify a protective order depends on the nature of the documents in question. There is a presumptive right of public access to judicial\n\nApp.119\nDOJ-OGR-00019578",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "The Honorable Alison J. Nathan\nAugust 24, 2020\nPage 5",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "Protective Orders May Be Modified As Circumstances Change\nFinally, the government suggests in a myriad of ways without directly arguing that this Protective Order cannot be modified, that Ms. Maxwell somehow waived her ability to seek modification by agreeing to a Protective Order before she knew what was contained in the criminal discovery, or that there is no precedent for such a modification. These suggestions are disingenuous. Of course, the Government ignores that the Protective Order itself provides that it may be modified \"by further order of the Court.\" Id., ¶ 18(b).",
+      "position": "top"
+    },
+    {
+      "type": "printed",
+      "content": "There is no precedence for this case. That is true because the Second Circuit has outlined a process for the government to seek civil materials subject to protective orders for use in grand jury investigations, a process the government circumvented. It also is true because typically, the government is the party to intervene in civil cases and seek a stay where materials the government has marked \"Confidential\" may be disclosed publicly or where the government contends the rules of criminal discovery will be circumvented. Finally, there is no other case that defense counsel has located where",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "That Ms. Maxwell did not know what was in the sealed materials before she signed the Protective Order, or proposed a draft, is self-evident. That a Court can modify a protective order at any time is likewise well-established. Fed. R. Crim. P. 16(d)(1) authorizes the Court to regulate discovery through protective orders and modification of those orders. See Smith Kline Beecham Corp. v. Synthon Pharmaceuticals, Ltd., 210 F.R.D. 163, 166 (M.D.N.C. 2002) (\"[c]ourts have the inherent power to modify protective orders, including protective orders arising from a stipulation by the parties\"); see also United States v. Gurney, 558 F.2d 1202, 1211 n.15 (5th Cir. 1977) (trial court's decisions as to which documents \"will be placed in the public domain, and which are entitled to privacy and confidentiality\" are discretionary and \"form an integral part of trial management\"); United States v. Wecht, 484 F.3d 194, 211 (3d Cir. 2007), as amended (July 2, 2007) (\"it would have been proper for the District Court to unseal the records pursuant to its general discretionary powers\"); Poliquin v. Garden Way, Inc., 989 F.2d 527, 532 & 535 (1st Cir. 1993).",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "\"The standard of review for a request to vacate or modify a protective order depends on the nature of the documents in question. There is a presumptive right of public access to judicial",
+      "position": "bottom"
+    },
+    {
+      "type": "printed",
+      "content": "App.119",
+      "position": "footer"
+    },
+    {
+      "type": "printed",
+      "content": "DOJ-OGR-00019578",
+      "position": "footer"
+    }
+  ],
+  "entities": {
+    "people": [
+      "Alison J. Nathan",
+      "Ms. Maxwell"
+    ],
+    "organizations": [
+      "Second Circuit",
+      "Government",
+      "Court",
+      "District Court"
+    ],
+    "locations": [],
+    "dates": [
+      "August 24, 2020",
+      "July 2, 2007"
+    ],
+    "reference_numbers": [
+      "120366006380",
+      "DOJ-OGR-00019578",
+      "210 F.R.D. 163",
+      "558 F.2d 1202",
+      "484 F.3d 194",
+      "989 F.2d 527"
+    ]
+  },
+  "additional_notes": "The document appears to be a court filing with redactions. The text is mostly clear, but some parts are blacked out."
+}