{
  "document_metadata": {
    "page_number": "1",
    "document_number": "612",
    "date": "January 13, 2022",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 612 Filed 02/24/22 Page 1 of 5\nHaddon, Morgan and Foreman, P.C\nJeffrey S. Pagliuca\n150 East 10th Avenue\nDenver, Colorado 80203\nPH 303.831.7364\nFX 303.832.2628\nwww.hmflaw.com\njpagliuca@hmflaw.com\nJanuary 13, 2022\nVIA EMAIL\nThe Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\n40 Foley Square\nNew York, NY 10007\nRe: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)\nDear Judge Nathan,\nMs. Maxwell requests that the \"Memorandum of Law in Support of Motion to Intervene and for Release of Sealed Jury Questionnaire and Transcript, on Behalf of Proposed Intervenor, Juror 50\" and its companion Motion remain under seal, at least until a resolution of Ms. Maxwell's forthcoming motion for new trial based on this Juror's failure to answer truthfully during jury selection. Juror 50's Motion and accompanying Memorandum are an attempt to obtain discovery by a non-party to this criminal case, made by someone who lacks standing to participate in this prosecution. Accordingly, these pleadings are not \"judicial documents\" and are afforded no presumption of public access.\nJuror 50 first seeks to intervene suggesting that \"it is indisputable that precedent supports intervention by interested third parties in criminal matters....\" Memo. at 8.\nAu contraire, \"the long line of precedent hold[s] that a non-party lacks a judicially cognizable interest in a defendant's prosecution.\" United States v. Stoerr, 695 F.3d 271, 278 (3d Cir. 2012). Juror 50 is not a party here and there is no legal basis for Juror 50 to intervene in this\nDOJ-OGR-00008997",
  "text_blocks": [
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      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 612 Filed 02/24/22 Page 1 of 5",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Haddon, Morgan and Foreman, P.C\nJeffrey S. Pagliuca\n150 East 10th Avenue\nDenver, Colorado 80203\nPH 303.831.7364\nFX 303.832.2628\nwww.hmflaw.com\njpagliuca@hmflaw.com",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "January 13, 2022\nVIA EMAIL\nThe Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\n40 Foley Square\nNew York, NY 10007\nRe: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)\nDear Judge Nathan,",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Ms. Maxwell requests that the \"Memorandum of Law in Support of Motion to Intervene and for Release of Sealed Jury Questionnaire and Transcript, on Behalf of Proposed Intervenor, Juror 50\" and its companion Motion remain under seal, at least until a resolution of Ms. Maxwell's forthcoming motion for new trial based on this Juror's failure to answer truthfully during jury selection. Juror 50's Motion and accompanying Memorandum are an attempt to obtain discovery by a non-party to this criminal case, made by someone who lacks standing to participate in this prosecution. Accordingly, these pleadings are not \"judicial documents\" and are afforded no presumption of public access.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Juror 50 first seeks to intervene suggesting that \"it is indisputable that precedent supports intervention by interested third parties in criminal matters....\" Memo. at 8.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Au contraire, \"the long line of precedent hold[s] that a non-party lacks a judicially cognizable interest in a defendant's prosecution.\" United States v. Stoerr, 695 F.3d 271, 278 (3d Cir. 2012). Juror 50 is not a party here and there is no legal basis for Juror 50 to intervene in this",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00008997",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Jeffrey S. Pagliuca",
      "Alison J. Nathan",
      "Ghislaine Maxwell"
    ],
    "organizations": [
      "Haddon, Morgan and Foreman, P.C",
      "United States District Court",
      "Southern District of New York"
    ],
    "locations": [
      "Denver",
      "Colorado",
      "New York"
    ],
    "dates": [
      "January 13, 2022",
      "02/24/22",
      "2012"
    ],
    "reference_numbers": [
      "Case 1:20-cr-00330-PAE",
      "Document 612",
      "20 Cr. 330 (AJN)",
      "DOJ-OGR-00008997"
    ]
  },
  "additional_notes": "The document appears to be a formal letter from a law firm to a judge, discussing a legal case involving Ghislaine Maxwell. The letter is typed and contains legal terminology and references to specific court documents."
}