{
  "document_metadata": {
    "page_number": "1",
    "document_number": "199",
    "date": "04/09/21",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 199 Filed 04/09/21 Page 1 of 8\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 9, 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 defense letter dated March 31, 2021 (Dkt. No. 192), and pursuant to the Court's Order dated April 2, 2021 (Dkt. No. 193). As set forth below, the timing of superseding indictment S2 20 Cr. 330 (AJN) (the \"S2 Indictment\") was dictated by developments in the Government's ongoing investigation, not the nefarious motivations suggested by the defense. Although trial may be modestly longer as a result, the S2 Indictment by no means opens the floodgate of witnesses the defense imagines; to the contrary, the Government expects to present a streamlined case focusing primarily on the four minor victims referenced in the S2 Indictment. Moreover, the Government has already taken, and will continue to take, steps to ensure that the defense will be fully prepared for trial as scheduled in July. Accordingly, the Government would oppose any request for an adjournment of trial.\nFinally, the addition of new charges, supported by even more evidence, in no way warrants reconsideration of this Court's three prior orders denying the defendant bail.\nFirst, the Government obtained the S2 Indictment based on new evidence that was not available to it at the time the defendant was indicted in 2020 or at the time Jeffrey Epstein was indicted in 2019. Specifically, although Minor Victim-4 had previously been interviewed once in",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 199 Filed 04/09/21 Page 1 of 8",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "U.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 9, 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 defense letter dated March 31, 2021 (Dkt. No. 192), and pursuant to the Court's Order dated April 2, 2021 (Dkt. No. 193). As set forth below, the timing of superseding indictment S2 20 Cr. 330 (AJN) (the \"S2 Indictment\") was dictated by developments in the Government's ongoing investigation, not the nefarious motivations suggested by the defense. Although trial may be modestly longer as a result, the S2 Indictment by no means opens the floodgate of witnesses the defense imagines; to the contrary, the Government expects to present a streamlined case focusing primarily on the four minor victims referenced in the S2 Indictment. Moreover, the Government has already taken, and will continue to take, steps to ensure that the defense will be fully prepared for trial as scheduled in July. Accordingly, the Government would oppose any request for an adjournment of trial.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Finally, the addition of new charges, supported by even more evidence, in no way warrants reconsideration of this Court's three prior orders denying the defendant bail.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "First, the Government obtained the S2 Indictment based on new evidence that was not available to it at the time the defendant was indicted in 2020 or at the time Jeffrey Epstein was indicted in 2019. Specifically, although Minor Victim-4 had previously been interviewed once in",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00002913",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ghislaine Maxwell",
      "Jeffrey Epstein"
    ],
    "organizations": [
      "U.S. Department of Justice",
      "United States Attorney",
      "United States District Court"
    ],
    "locations": [
      "New York",
      "Southern District of New York"
    ],
    "dates": [
      "April 9, 2021",
      "March 31, 2021",
      "April 2, 2021",
      "2020",
      "2019",
      "July"
    ],
    "reference_numbers": [
      "20 Cr. 330 (AJN)",
      "Dkt. No. 192",
      "Dkt. No. 193",
      "Case 1:20-cr-00330-PAE",
      "Document 199"
    ]
  },
  "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 typed and contains no handwritten text or stamps."
}