{
  "document_metadata": {
    "page_number": "5",
    "document_number": "20-cr-0030",
    "date": "2021",
    "document_type": "Legal Document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "years and elected to commence prosecution of Ms. Maxwell in the throes of the pandemic. All counsel have been laboring under the difficulties caused by this unprecedented circumstance.\nThe government's challenges pale in comparison to those experienced by the defense.\nDefending quarter-century-old allegations has required investigation across this country and around the world. Investigating the new allegations will require the same efforts and diligence.\nIt is laughable for the government to use COVID as an excuse for its delay in superseding the indictment and then oppose any continuance for the defense. Defense preparation is not immune to the impact of the pandemic.\nA Trial Continuance is Necessary\nWhile the government's offer to provide discovery highlights and its representation that it will streamline its case to primarily focus on the four accusers are helpful, these gestures do not eliminate the need for a continuance. As set forth above, the government's hyperbolic claim that it can \"ensure that the defense will be fully prepared to proceed to trial on July 12, 2021\" (Govt ltr at 4-5) ignores the reality that time is needed to:\n- supplement pending pretrial motions;\n- critically review voluminous discovery produced in November 2020 that the government represented was not relevant to the case against Ms. Maxwell;\n- re-review discovery for the new time period and charges;\n- commence new investigations based on the new charges and the government's disclosure of 3500 material for non-testifying witnesses; and\n- refocus trial preparation and strategy.\nThe government originally represented to the Court and counsel that this trial would last two weeks. The government now predicts the trial will last a month. The estimates are mere guesses which do not factor in time-consuming COVID jury selection in a high-publicity case necessitating sensitive and personal disclosures by prospective jurors or the presentation of defense evidence. In the absence of disclosure of the number and identity of government trial",
  "text_blocks": [
    {
      "type": "printed",
      "content": "years and elected to commence prosecution of Ms. Maxwell in the throes of the pandemic. All counsel have been laboring under the difficulties caused by this unprecedented circumstance.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The government's challenges pale in comparison to those experienced by the defense.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Defending quarter-century-old allegations has required investigation across this country and around the world. Investigating the new allegations will require the same efforts and diligence.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "It is laughable for the government to use COVID as an excuse for its delay in superseding the indictment and then oppose any continuance for the defense. Defense preparation is not immune to the impact of the pandemic.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "A Trial Continuance is Necessary",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "While the government's offer to provide discovery highlights and its representation that it will streamline its case to primarily focus on the four accusers are helpful, these gestures do not eliminate the need for a continuance. As set forth above, the government's hyperbolic claim that it can \"ensure that the defense will be fully prepared to proceed to trial on July 12, 2021\" (Govt ltr at 4-5) ignores the reality that time is needed to:",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "- supplement pending pretrial motions;\n- critically review voluminous discovery produced in November 2020 that the government represented was not relevant to the case against Ms. Maxwell;\n- re-review discovery for the new time period and charges;\n- commence new investigations based on the new charges and the government's disclosure of 3500 material for non-testifying witnesses; and\n- refocus trial preparation and strategy.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The government originally represented to the Court and counsel that this trial would last two weeks. The government now predicts the trial will last a month. The estimates are mere guesses which do not factor in time-consuming COVID jury selection in a high-publicity case necessitating sensitive and personal disclosures by prospective jurors or the presentation of defense evidence. In the absence of disclosure of the number and identity of government trial",
      "position": "bottom"
    }
  ],
  "entities": {
    "people": [
      "Ms. Maxwell",
      "Bobbi C. Sternheim"
    ],
    "organizations": [
      "LAW OFFICES OF BOBBI C. STERNHEIM",
      "Court"
    ],
    "locations": [],
    "dates": [
      "July 12, 2021",
      "November 2020"
    ],
    "reference_numbers": [
      "20-cr-0030",
      "DOJ-OGR-00001393"
    ]
  },
  "additional_notes": "The document appears to be a legal filing related to the case against Ms. Maxwell. The text discusses the challenges faced by the defense due to the COVID-19 pandemic and the need for a trial continuance. The document is well-formatted and free of significant damage or redactions."
}