{
  "document_metadata": {
    "page_number": "2",
    "document_number": "276",
    "date": "05/11/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 276 Filed 05/11/21 Page 2 of 4\nLAW OFFICES OF BOBBI C. STERNHEIM\n8th. Ms. Maxwell's other trial counsel are committed to un-moveable trials in September and October. We have provided all the details concerning those conflicts and sought, as the Court directed, to move other conflicting dates. Considering Ms. Maxwell's extended period of detention, and its deleterious effect on her health and well-being, we cannot agree to a date far beyond November 8th.\nIn response to our efforts to meet and confer, the only date the government offered was November 29th. When asked to explain with details similar to those conveyed by defense counsel, the government replied at 6:00 p.m. this evening simply that November 29th was necessary to provide \"continuity of counsel and the potential unavailability of a trial witness.\" The government failed to disclose which counsel needed to continue on the case, nor the \"potential unavailability\" of which trial witness. There was no meaningful conferral. Previously, of course, the government took the position that its accusers wanted the soonest possible trial date.\nThe government's requests to defer the trial from November 8th to a November 29th start date rest on faulty premises. First, they contend, \"continuity of counsel\" is needed so that one of the four assigned Assistant U.S. Attorneys can be available to try this case. In the initial stages of our review of the 20,000 plus pages of non-testifying witness statements, is clear that two of the other assigned AUSAs have been involved from the very beginning of this investigation and have actively participated in all of the interviews together. They were joined as often as not by yet a fourth AUSA who previously was assigned to this case and who still works in their office.\nNotably the government does not claim that the three remaining assistants are unfamiliar with the facts or law of the case, nor that they are not competent trial counsel.\nSecond, the government points to a \"potential\" conflict of one witness who reportedly is unavailable (for unknown reasons) for nearly two months — all of October through to\n2\nDOJ-OGR-00004118",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 276 Filed 05/11/21 Page 2 of 4",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "LAW OFFICES OF BOBBI C. STERNHEIM",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "8th. Ms. Maxwell's other trial counsel are committed to un-moveable trials in September and October. We have provided all the details concerning those conflicts and sought, as the Court directed, to move other conflicting dates. Considering Ms. Maxwell's extended period of detention, and its deleterious effect on her health and well-being, we cannot agree to a date far beyond November 8th.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "In response to our efforts to meet and confer, the only date the government offered was November 29th. When asked to explain with details similar to those conveyed by defense counsel, the government replied at 6:00 p.m. this evening simply that November 29th was necessary to provide \"continuity of counsel and the potential unavailability of a trial witness.\" The government failed to disclose which counsel needed to continue on the case, nor the \"potential unavailability\" of which trial witness. There was no meaningful conferral. Previously, of course, the government took the position that its accusers wanted the soonest possible trial date.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "The government's requests to defer the trial from November 8th to a November 29th start date rest on faulty premises. First, they contend, \"continuity of counsel\" is needed so that one of the four assigned Assistant U.S. Attorneys can be available to try this case. In the initial stages of our review of the 20,000 plus pages of non-testifying witness statements, is clear that two of the other assigned AUSAs have been involved from the very beginning of this investigation and have actively participated in all of the interviews together. They were joined as often as not by yet a fourth AUSA who previously was assigned to this case and who still works in their office.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Notably the government does not claim that the three remaining assistants are unfamiliar with the facts or law of the case, nor that they are not competent trial counsel.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Second, the government points to a \"potential\" conflict of one witness who reportedly is unavailable (for unknown reasons) for nearly two months — all of October through to",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "2",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00004118",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Ms. Maxwell",
      "Bobbi C. Sternheim"
    ],
    "organizations": [
      "LAW OFFICES OF BOBBI C. STERNHEIM",
      "U.S. Attorneys"
    ],
    "locations": [],
    "dates": [
      "September",
      "October",
      "November 8th",
      "November 29th",
      "May 11, 2021"
    ],
    "reference_numbers": [
      "Case 1:20-cr-00330-AJN",
      "Document 276",
      "DOJ-OGR-00004118"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Ms. Maxwell. The text is printed and legible. There are no visible stamps or handwritten annotations."
}