{
  "document_metadata": {
    "page_number": "1",
    "document_number": "229",
    "date": "04/21/21",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 229 Filed 04/21/21 Page 1 of 5\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\nApril 21, 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 submits this letter in response to the Court's Order dated April 16, 2021, which directed the parties to negotiate a final schedule for all remaining pretrial matters in the above-referenced case. (Dkt. No. 207). Although the parties have agreed upon a schedule for several pretrial matters, the parties have not reached complete agreement on a full schedule. Accordingly, the Government is submitting this letter containing its proposal, and understands that defense counsel will write separately to convey the defense's competing proposal.\nBased on conversations with defense counsel, the Government understands that the parties agree on the following proposed dates, assuming trial begins as scheduled on July 12, 2021:\n- The Government will provide expert notice to the defense by April 23, 2021.\n- The defense shall file any additional or supplemental motion briefing in light of the S2 Indictment by May 7, 2021. The Government shall file its responsive briefing by May 21, 2021. The defense shall file any reply briefing by May 28, 2021.\n- The Government will provide the defense with the identities of the victims referenced in the S2 Indictment by May 17, 2021.\nDOJ-OGR-00003922",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 229 Filed 04/21/21 Page 1 of 5",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "U.S. Department of Justice\nUnited States Attorney\nSouthern District of New York",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "The Silvio J. Mollo Building\nOne Saint Andrew's Plaza\nNew York, New York 10007",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "April 21, 2021",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "BY ECF",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The 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": "top"
    },
    {
      "type": "printed",
      "content": "Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Dear Judge Nathan:",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The Government respectfully submits this letter in response to the Court's Order dated April 16, 2021, which directed the parties to negotiate a final schedule for all remaining pretrial matters in the above-referenced case. (Dkt. No. 207). Although the parties have agreed upon a schedule for several pretrial matters, the parties have not reached complete agreement on a full schedule. Accordingly, the Government is submitting this letter containing its proposal, and understands that defense counsel will write separately to convey the defense's competing proposal.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Based on conversations with defense counsel, the Government understands that the parties agree on the following proposed dates, assuming trial begins as scheduled on July 12, 2021:",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "- The Government will provide expert notice to the defense by April 23, 2021.\n- The defense shall file any additional or supplemental motion briefing in light of the S2 Indictment by May 7, 2021. The Government shall file its responsive briefing by May 21, 2021. The defense shall file any reply briefing by May 28, 2021.\n- The Government will provide the defense with the identities of the victims referenced in the S2 Indictment by May 17, 2021.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00003922",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ghislaine Maxwell"
    ],
    "organizations": [
      "U.S. Department of Justice",
      "United States Attorney",
      "United States District Court"
    ],
    "locations": [
      "New York",
      "Southern District of New York"
    ],
    "dates": [
      "April 21, 2021",
      "April 16, 2021",
      "July 12, 2021",
      "April 23, 2021",
      "May 7, 2021",
      "May 21, 2021",
      "May 28, 2021",
      "May 17, 2021"
    ],
    "reference_numbers": [
      "20 Cr. 330 (AJN)",
      "Dkt. No. 207",
      "DOJ-OGR-00003922"
    ]
  },
  "additional_notes": "The document appears to be a formal letter from the U.S. Department of Justice to the Honorable Alison J. Nathan, regarding the case United States v. Ghislaine Maxwell. The letter is dated April 21, 2021, and is filed electronically via ECF. The document is well-formatted and free of significant damage or redactions."
}