{
  "document_metadata": {
    "page_number": "1 of 2",
    "document_number": "107",
    "date": "12/31/20",
    "document_type": "court filing",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 107 Filed 12/31/20 Page 1 of 2\nCOHEN & GRESSER LLP\nChristian R. Everdell\n+1 (212) 957-7600\neverdell@cohengresser.com\n800 Third Avenue\nNew York, NY 10022\n+1 212 957 7600 phone\nwww.cohengresser.com\nDecember 31, 2020\nBY ECF\nThe Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\nUnited States Courthouse\n40 Foley Square\nNew York, NY 10007\nRe: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)\nDear Judge Nathan:\nWe write on behalf of our client, Ghislaine Maxwell, to respectfully request a two-week extension of time to file our pretrial motions and to shift the other motion deadlines forward by two weeks. We have conferred with the government, which has consented to the requested extension and the modified briefing schedule. The requested extension is necessary given the large volume of discovery produced by the government, which we are still reviewing, and to ensure that defense counsel can adequately discuss the motions with our client and have her review them. As the Court is aware, Ms. Maxwell was recently placed in quarantine for 14 days and in-person legal visits at MDC have been indefinitely suspended due to COVID, which has constrained our ability to confer with her.\nUnder the Court's original briefing schedule, the defendant's pretrial motions were due on December 21, 2020, the government's response was due January 22, 2021, and the defendant's reply was due on February 5, 2021. (Dkt. 25). The Court agreed to move those deadlines by three weeks because the government needed additional time to finish producing discovery. (Dkt. 72). Under the current briefing schedule, the defendant's pretrial motions are due on January 11, 2020, the government's response is due February 12, 2021, and the defendant's reply is due on February 19, 2021. (Id.). We respectfully request that the Court so order the briefing schedule below. The next scheduled appearance before the Court is the first day of trial on July 12, 2021.\nJanuary 25, 2021 Defendant's pretrial motions due\nFebruary 26, 2021 Government's response due\nMarch 5, 2021 Defendant's reply due\nDOJ-OGR-00002255",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 107 Filed 12/31/20 Page 1 of 2",
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    },
    {
      "type": "printed",
      "content": "COHEN & GRESSER LLP",
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    {
      "type": "printed",
      "content": "Christian R. Everdell\n+1 (212) 957-7600\neverdell@cohengresser.com",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "800 Third Avenue\nNew York, NY 10022\n+1 212 957 7600 phone\nwww.cohengresser.com",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "December 31, 2020",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "BY ECF\nThe Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\nUnited States Courthouse\n40 Foley Square\nNew 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:",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "We write on behalf of our client, Ghislaine Maxwell, to respectfully request a two-week extension of time to file our pretrial motions and to shift the other motion deadlines forward by two weeks. We have conferred with the government, which has consented to the requested extension and the modified briefing schedule. The requested extension is necessary given the large volume of discovery produced by the government, which we are still reviewing, and to ensure that defense counsel can adequately discuss the motions with our client and have her review them. As the Court is aware, Ms. Maxwell was recently placed in quarantine for 14 days and in-person legal visits at MDC have been indefinitely suspended due to COVID, which has constrained our ability to confer with her.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Under the Court's original briefing schedule, the defendant's pretrial motions were due on December 21, 2020, the government's response was due January 22, 2021, and the defendant's reply was due on February 5, 2021. (Dkt. 25). The Court agreed to move those deadlines by three weeks because the government needed additional time to finish producing discovery. (Dkt. 72). Under the current briefing schedule, the defendant's pretrial motions are due on January 11, 2020, the government's response is due February 12, 2021, and the defendant's reply is due on February 19, 2021. (Id.). We respectfully request that the Court so order the briefing schedule below. The next scheduled appearance before the Court is the first day of trial on July 12, 2021.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "January 25, 2021 Defendant's pretrial motions due\nFebruary 26, 2021 Government's response due\nMarch 5, 2021 Defendant's reply due",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00002255",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Christian R. Everdell",
      "Alison J. Nathan",
      "Ghislaine Maxwell"
    ],
    "organizations": [
      "COHEN & GRESSER LLP",
      "United States District Court",
      "Southern District of New York"
    ],
    "locations": [
      "New York",
      "NY",
      "United States Courthouse",
      "40 Foley Square"
    ],
    "dates": [
      "December 31, 2020",
      "December 21, 2020",
      "January 22, 2021",
      "February 5, 2021",
      "January 11, 2021",
      "February 12, 2021",
      "February 19, 2021",
      "January 25, 2021",
      "February 26, 2021",
      "March 5, 2021",
      "July 12, 2021"
    ],
    "reference_numbers": [
      "20 Cr. 330 (AJN)",
      "Dkt. 25",
      "Dkt. 72",
      "DOJ-OGR-00002255"
    ]
  },
  "additional_notes": "The document appears to be a court filing in the case United States v. Ghislaine Maxwell. The letter is from Christian R. Everdell of COHEN & GRESSER LLP, requesting a two-week extension of time to file pretrial motions. The document is well-formatted and free of significant damage or redactions."
}