{
  "document_metadata": {
    "page_number": "1",
    "document_number": "3769",
    "date": "October 25, 2021",
    "document_type": "Letter",
    "has_handwriting": true,
    "has_stamps": true
  },
  "full_text": "Case #: 2020-cr-00338 (AJN) Document #: 3769 Filed: 10/26/21 Page 1 of 1 COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 +1 212 957 7600 phone www.cohengresser.com Christian R. Everdell +1 (212) 957-7600 ceverdell@cohengresser.com October 25, 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 USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC #: DATE FILED: 10/26/21 Re: United States v. Ghislaine Maxwell, S2 20 Cr. 330 (AJN) Dear Judge Nathan: SO ORDERED. Alison J. Nathan 10/26/21 We respectfully submit this letter to request a one-week extension until November 3, 2021, to file the joint proposed jury charge and verdict sheet, which are currently due on October 27, 2021. See 8/27/2021 Order (Dkt. 330). The government consents to this request. On October 20, 2021, the government provided the defense with its proposed jury charge. Because of the press of other deadlines in this case—including the motions in limine responses and replies, and the Rule 12 briefing—the defense requests an additional week to provide its counterproposals to the government and to submit the final proposed jury charge to the Court. The government and the defense have met and conferred and agreed that the defense will send the government a redlined version of the government’s proposed jury charge containing the defense’s counterproposals by 7:00 p.m. on November 1, 2021. The parties will submit the final joint proposed request to charge and verdict sheet, with the areas of continued disagreement shown in redline, on November 3, 2021. We respectfully request that the Court approve this revised schedule. Sincerely, /s/ Christian Everdell Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue, 21st Floor New York, New York 10022 (212) 957-7600 cc: All Counsel of Record (By ECF) DOJ-OGR-00005379",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case #: 2020-cr-00338 (AJN) Document #: 3769 Filed: 10/26/21 Page 1 of 1",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 +1 212 957 7600 phone www.cohengresser.com",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Christian R. Everdell +1 (212) 957-7600 ceverdell@cohengresser.com",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "October 25, 2021",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "BY ECF",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "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": "middle"
    },
    {
      "type": "stamp",
      "content": "USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC #: DATE FILED: 10/26/21",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Re: United States v. Ghislaine Maxwell, S2 20 Cr. 330 (AJN)",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Dear Judge Nathan:",
      "position": "middle"
    },
    {
      "type": "handwritten",
      "content": "SO ORDERED. Alison J. Nathan 10/26/21",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "We respectfully submit this letter to request a one-week extension until November 3, 2021, to file the joint proposed jury charge and verdict sheet, which are currently due on October 27, 2021. See 8/27/2021 Order (Dkt. 330). The government consents to this request.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "On October 20, 2021, the government provided the defense with its proposed jury charge. Because of the press of other deadlines in this case—including the motions in limine responses and replies, and the Rule 12 briefing—the defense requests an additional week to provide its counterproposals to the government and to submit the final proposed jury charge to the Court.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The government and the defense have met and conferred and agreed that the defense will send the government a redlined version of the government’s proposed jury charge containing the defense’s counterproposals by 7:00 p.m. on November 1, 2021. The parties will submit the final joint proposed request to charge and verdict sheet, with the areas of continued disagreement shown in redline, on November 3, 2021. We respectfully request that the Court approve this revised schedule.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Sincerely,",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "/s/ Christian Everdell Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue, 21st Floor New York, New York 10022 (212) 957-7600",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "cc: All Counsel of Record (By ECF)",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00005379",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Christian R. Everdell",
      "Ghislaine Maxwell"
    ],
    "organizations": [
      "COHEN & GRESSER LLP",
      "United States District Court",
      "United States Courthouse"
    ],
    "locations": [
      "New York",
      "Southern District of New York"
    ],
    "dates": [
      "October 25, 2021",
      "October 27, 2021",
      "November 3, 2021",
      "October 20, 2021",
      "August 27, 2021",
      "November 1, 2021"
    ],
    "reference_numbers": [
      "2020-cr-00338 (AJN)",
      "S2 20 Cr. 330 (AJN)",
      "Dkt. 330",
      "3769",
      "DOJ-OGR-00005379"
    ]
  },
  "additional_notes": "The document is a letter from Christian R. Everdell to Judge Alison J. Nathan requesting an extension to file the joint proposed jury charge and verdict sheet in the case United States v. Ghislaine Maxwell. The letter is signed by Christian R. Everdell and includes a stamp indicating that it was electronically filed with the court on October 26, 2021."
}