{
  "document_metadata": {
    "page_number": "1",
    "document_number": "192",
    "date": "03/31/21",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 192 Filed 03/31/21 Page 1 of 3\n\nLAW OFFICES OF BOBBI C. STERNHEIM\n\n212-243-1100 • Main\n917-306-6666 • Cell\n888-587-4737 • Fax\n\n33 West 19th Street - 4th Floor\nNew York, New York 10011\nbc@sternheimlaw.com\n\nMarch 31, 2021\n\nHonorable Alison J. Nathan\nUnited States District Judge\nUnited States Courthouse\n40 Foley Square\nNew York, NY 10007\n\nUnited States v. Ghislaine Maxwell\nS2 20 Cr. 330 (AJN)\n\nDear Judge Nathan:\n\nThis week's filing of the second superseding indictment presents new and complicating issues. In addition to expanding a three-year conspiracy to 10 years, the government has added two serious charges that drastically change the focus of this case. That the government has made this move late in the game - with trial set for July 12th - is obvious tactical gamesmanship. Adding charges that were never launched against Jeffrey Epstein based on evidence that was in the government's possession for years is shocking, unfair, and an abuse of power. More than doubling the time period of the originally charged conspiracy from 1994 to 2004 (previously 1997) and alleging two distinctly different substantive counts requires: additional investigation; requests for additional discovery; the need to supplement pretrial motions that have fully briefed and are pending before the Court; and the drafting and filing of additional motions pertinent to the new indictment. Accordingly, a new briefing schedule is required.\n\nEven more concerning is the impact this late-breaking filing has on Ms. Maxwell's constitutional rights. Her liberty interests now clash with her right to effective assistance of counsel. The Court is aware of the extraordinary circumstances of Ms. Maxwell's detention, its deleterious effect on her health and well-being, and the realistic concern whether she will be strong enough to withstand the stress of trial.\n\nCounsel have not yet determined whether to formally move for a continuance. This decision is not an easy one. Ms. Maxwell and her lawyers have been diligently preparing for trial. However, the government's continued refusal to provide the most basic discovery - names of accusers - coupled with what amounts to a new indictment (after what was supposed to be the trial preparation from moving forward in an orderly manner. Accordingly, we have requested an opportunity to confer with government counsel with the goal of clarifying the necessity of moving the trial date.\n\nDOJ-OGR-00002884",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 192 Filed 03/31/21 Page 1 of 3",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "LAW OFFICES OF BOBBI C. STERNHEIM",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "212-243-1100 • Main\n917-306-6666 • Cell\n888-587-4737 • Fax",
      "position": "left margin"
    },
    {
      "type": "printed",
      "content": "33 West 19th Street - 4th Floor\nNew York, New York 10011\nbc@sternheimlaw.com",
      "position": "right margin"
    },
    {
      "type": "printed",
      "content": "March 31, 2021",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Honorable Alison J. Nathan\nUnited States District Judge\nUnited States Courthouse\n40 Foley Square\nNew York, NY 10007",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "United States v. Ghislaine Maxwell\nS2 20 Cr. 330 (AJN)",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Dear Judge Nathan:",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "This week's filing of the second superseding indictment presents new and complicating issues. In addition to expanding a three-year conspiracy to 10 years, the government has added two serious charges that drastically change the focus of this case. That the government has made this move late in the game - with trial set for July 12th - is obvious tactical gamesmanship. Adding charges that were never launched against Jeffrey Epstein based on evidence that was in the government's possession for years is shocking, unfair, and an abuse of power. More than doubling the time period of the originally charged conspiracy from 1994 to 2004 (previously 1997) and alleging two distinctly different substantive counts requires: additional investigation; requests for additional discovery; the need to supplement pretrial motions that have fully briefed and are pending before the Court; and the drafting and filing of additional motions pertinent to the new indictment. Accordingly, a new briefing schedule is required.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Even more concerning is the impact this late-breaking filing has on Ms. Maxwell's constitutional rights. Her liberty interests now clash with her right to effective assistance of counsel. The Court is aware of the extraordinary circumstances of Ms. Maxwell's detention, its deleterious effect on her health and well-being, and the realistic concern whether she will be strong enough to withstand the stress of trial.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Counsel have not yet determined whether to formally move for a continuance. This decision is not an easy one. Ms. Maxwell and her lawyers have been diligently preparing for trial. However, the government's continued refusal to provide the most basic discovery - names of accusers - coupled with what amounts to a new indictment (after what was supposed to be the trial preparation from moving forward in an orderly manner. Accordingly, we have requested an opportunity to confer with government counsel with the goal of clarifying the necessity of moving the trial date.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00002884",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ghislaine Maxwell",
      "Jeffrey Epstein"
    ],
    "organizations": [
      "LAW OFFICES OF BOBBI C. STERNHEIM",
      "United States Courthouse"
    ],
    "locations": [
      "New York",
      "Foley Square"
    ],
    "dates": [
      "March 31, 2021",
      "July 12th",
      "1994",
      "2004",
      "1997"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "Document 192",
      "S2 20 Cr. 330 (AJN)",
      "DOJ-OGR-00002884"
    ]
  },
  "additional_notes": "The document appears to be a formal letter from the Law Offices of Bobbi C. Sternheim to Judge Alison J. Nathan regarding the case United States v. Ghislaine Maxwell. The letter discusses the recent filing of a second superseding indictment and its implications on the trial. The document is well-formatted and free of significant damage or redactions."
}