{
  "document_metadata": {
    "page_number": "1 of 3",
    "document_number": "230",
    "date": "04/21/21",
    "document_type": "Court Document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 230 Filed 04/21/21 Page 1 of 3 COHEN & GRESSER LLP Christian R. Everdell +1 (212) 957-7600 ceverdell@cohengresser.com 800 Third Avenue New York, NY 10022 +1 212 957 7600 phone www.cohengresser.com April 21, 2021 BY ECF The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: Pursuant to the Court's Opinion and Order, dated April 16, 2021 (Dkt. 207), the parties have met and conferred about a schedule for the remaining pretrial disclosures and other pretrial motions practice. Although Ms. Maxwell maintains that a continuance of the trial date is necessary to ensure a fair trial for the reasons we will set forth in our letter to the Court tomorrow, we have discussed with the government disclosure dates assuming the trial begins on July 12, 2021. The following schedule indicates the areas of agreement and disagreement between the parties. Areas of agreement include dates proposed by both parties (in bold). Areas of disagreement include dates proposed by the defense (in bold) and dates proposed by the government (underlined). Parties Agree Government Expert Witness Disclosure April 23 - Government expert disclosure DOJ-OGR-00003927",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 230 Filed 04/21/21 Page 1 of 3",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "COHEN & GRESSER LLP",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Christian R. Everdell +1 (212) 957-7600 ceverdell@cohengresser.com",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "800 Third Avenue New York, NY 10022 +1 212 957 7600 phone www.cohengresser.com",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "April 21, 2021",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "BY ECF The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, NY 10007",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Dear Judge Nathan: Pursuant to the Court's Opinion and Order, dated April 16, 2021 (Dkt. 207), the parties have met and conferred about a schedule for the remaining pretrial disclosures and other pretrial motions practice. Although Ms. Maxwell maintains that a continuance of the trial date is necessary to ensure a fair trial for the reasons we will set forth in our letter to the Court tomorrow, we have discussed with the government disclosure dates assuming the trial begins on July 12, 2021. The following schedule indicates the areas of agreement and disagreement between the parties. Areas of agreement include dates proposed by both parties (in bold). Areas of disagreement include dates proposed by the defense (in bold) and dates proposed by the government (underlined).",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Parties Agree Government Expert Witness Disclosure April 23 - Government expert disclosure",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00003927",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Christian R. Everdell",
      "Alison J. Nathan",
      "Ghislaine Maxwell"
    ],
    "organizations": [
      "COHEN & GRESSER LLP",
      "United States District Court",
      "United States Courthouse"
    ],
    "locations": [
      "New York",
      "NY",
      "Third Avenue",
      "Foley Square"
    ],
    "dates": [
      "April 21, 2021",
      "April 16, 2021",
      "July 12, 2021",
      "April 23"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 230",
      "20 Cr. 330 (AJN)",
      "Dkt. 207",
      "DOJ-OGR-00003927"
    ]
  },
  "additional_notes": "The document appears to be a court filing in the case United States v. Ghislaine Maxwell. It is a letter from Christian R. Everdell to Judge Alison J. Nathan discussing the schedule for pretrial disclosures and motions practice. The document is well-formatted and legible."
}