{
  "document_metadata": {
    "page_number": "1",
    "document_number": "41114",
    "date": "November 4, 2021",
    "document_type": "Court Document",
    "has_handwriting": true,
    "has_stamps": false
  },
  "full_text": "Case#: 2020cr00383(PAE) Document#: 41114 Filed: 11/4/2021 Page#: 1 of 3\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\nUSDCD SDNY\nDOCUMENT\nELECTRONICALLY FILED\nDOC #:\nDATE FILED: 11/4/21\nNovember 4, 2021\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 moves for reconsideration of the portions of the Court's order dated November 3, 2021 (Dkt. No. 409), directing the Government to file by November 8, 2021, any briefing to exclude any defense witness testimony disclosed on November 1, 2021, with defense responses due November 11, 2021.\nThis schedule provides the Government seven days—or six, if timed from the Court's order—to respond to the defense's expert notice, in which they gave notice for the first time of eight potential experts. By contrast, the Government notes that it provided the defense with notice of its expert on April 23, 2021, and the defense filed its motion to preclude on October 18, 2021.1\nMoreover, during that time, the Government will be (1) preparing for the November 10, 2021 Daubert hearing; (2) responding to the defendant's motion for reconsideration regarding disclosure of juror names (Dkt. No. 407); (3) providing the defense with categories of its co-conspirator statements and exemplars; (4) briefing the admissibility of Minor Victim-3's testimony\nThe Court hereby DENIES the Government's request as to Dr. Park Dietz and Dr. Elizabeth Loftus. Pursuant to this Court's Order, if the Government seeks to exclude these anticipated witnesses, briefing must be submitted by November 8, 2021. Dkt. No. 409. As to the remaining individuals disclosed in Defendant's notice, the Court GRANTS the Government's request. If the Government seeks to exclude those anticipated witnesses, briefing must be submitted by November 15, 2021, with a response by Defendant due November 19, 2021. SO ORDERED.\nAlison J. Nathan\n11/4/21\n1 The Government also provided expert notice of a witness who it does not believe requires admission through Rule 702 on September 15, 2021. The defense has not moved to preclude that witness.\nDOJ-OGR-00006169",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case#: 2020cr00383(PAE) Document#: 41114 Filed: 11/4/2021 Page#: 1 of 3",
      "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": "USDCD SDNY\nDOCUMENT\nELECTRONICALLY FILED\nDOC #:\nDATE FILED: 11/4/21",
      "position": "left margin"
    },
    {
      "type": "printed",
      "content": "November 4, 2021",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "BY 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",
      "position": "left"
    },
    {
      "type": "printed",
      "content": "Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Dear Judge Nathan:",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The Government respectfully moves for reconsideration of the portions of the Court's order dated November 3, 2021 (Dkt. No. 409), directing the Government to file by November 8, 2021, any briefing to exclude any defense witness testimony disclosed on November 1, 2021, with defense responses due November 11, 2021.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "This schedule provides the Government seven days—or six, if timed from the Court's order—to respond to the defense's expert notice, in which they gave notice for the first time of eight potential experts. By contrast, the Government notes that it provided the defense with notice of its expert on April 23, 2021, and the defense filed its motion to preclude on October 18, 2021.1",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Moreover, during that time, the Government will be (1) preparing for the November 10, 2021 Daubert hearing; (2) responding to the defendant's motion for reconsideration regarding disclosure of juror names (Dkt. No. 407); (3) providing the defense with categories of its co-conspirator statements and exemplars; (4) briefing the admissibility of Minor Victim-3's testimony",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The Court hereby DENIES the Government's request as to Dr. Park Dietz and Dr. Elizabeth Loftus. Pursuant to this Court's Order, if the Government seeks to exclude these anticipated witnesses, briefing must be submitted by November 8, 2021. Dkt. No. 409. As to the remaining individuals disclosed in Defendant's notice, the Court GRANTS the Government's request. If the Government seeks to exclude those anticipated witnesses, briefing must be submitted by November 15, 2021, with a response by Defendant due November 19, 2021. SO ORDERED.",
      "position": "middle"
    },
    {
      "type": "handwritten",
      "content": "Alison J. Nathan\n11/4/21",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "1 The Government also provided expert notice of a witness who it does not believe requires admission through Rule 702 on September 15, 2021. The defense has not moved to preclude that witness.",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00006169",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ghislaine Maxwell",
      "Dr. Park Dietz",
      "Dr. Elizabeth Loftus",
      "Minor Victim-3"
    ],
    "organizations": [
      "U.S. Department of Justice",
      "United States Attorney",
      "United States District Court",
      "Southern District of New York"
    ],
    "locations": [
      "New York"
    ],
    "dates": [
      "November 4, 2021",
      "November 3, 2021",
      "November 8, 2021",
      "November 1, 2021",
      "November 11, 2021",
      "April 23, 2021",
      "October 18, 2021",
      "November 10, 2021",
      "September 15, 2021",
      "November 15, 2021",
      "November 19, 2021"
    ],
    "reference_numbers": [
      "20 Cr. 330 (AJN)",
      "Dkt. No. 409",
      "Dkt. No. 407",
      "DOJ-OGR-00006169"
    ]
  },
  "additional_notes": "The document appears to be a court filing in the case United States v. Ghislaine Maxwell. It is a formal letter to Judge Alison J. Nathan from the U.S. Department of Justice, discussing a motion for reconsideration regarding the exclusion of certain witnesses. The document is signed by the judge and includes a handwritten date."
}