{
  "document_metadata": {
    "page_number": "2 of 3",
    "document_number": "384-1",
    "date": "October 11, 2021",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 384-1 Filed 10/29/21 Page 2 of 3 U.S Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 October 11, 2021 BY ELECTRONIC MAIL Christian Everdell, Esq. Cohen & Gresser LLP 800 Third Avenue New York, NY 10022 Laura Menninger, Esq. Jeffrey Pagliuca, Esq. Haddon, Morgan and Foreman, P.C. 150 East Tenth Avenue Denver, CO 80203 Bobbi Sternheim, Esq. Law Offices of Bobbi C. Sternheim 33 West 19th Street-4th Fl. New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Counsel: Pursuant to Judge Nathan's Order of September 3, 2021 (Dkt. No. 335), the Government writes to inform you that it may refer at trial to the following individuals as co-conspirators of the defendant, including for the purpose of Fed. R. Evid. 801(d)(2)(E): Jeffrey Epstein The Government has produced all co-conspirator statements which it intends to offer at trial pursuant to Fed. R. Evid. 801(d)(2)(E) in the Government's production today or in its previous productions. To the extent the Government learns of additional co-conspirator statements as it continues to prepare for trial, it will produce those statements in connection with its ongoing obligation to produce Jencks Act material. DOJ-OGR-00005608",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 384-1 Filed 10/29/21 Page 2 of 3",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "U.S Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 October 11, 2021",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "BY ELECTRONIC MAIL Christian Everdell, Esq. Cohen & Gresser LLP 800 Third Avenue New York, NY 10022 Laura Menninger, Esq. Jeffrey Pagliuca, Esq. Haddon, Morgan and Foreman, P.C. 150 East Tenth Avenue Denver, CO 80203 Bobbi Sternheim, Esq. Law Offices of Bobbi C. Sternheim 33 West 19th Street-4th Fl. New York, NY 10007",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Dear Counsel: Pursuant to Judge Nathan's Order of September 3, 2021 (Dkt. No. 335), the Government writes to inform you that it may refer at trial to the following individuals as co-conspirators of the defendant, including for the purpose of Fed. R. Evid. 801(d)(2)(E): Jeffrey Epstein The Government has produced all co-conspirator statements which it intends to offer at trial pursuant to Fed. R. Evid. 801(d)(2)(E) in the Government's production today or in its previous productions. To the extent the Government learns of additional co-conspirator statements as it continues to prepare for trial, it will produce those statements in connection with its ongoing obligation to produce Jencks Act material.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00005608",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Christian Everdell",
      "Laura Menninger",
      "Jeffrey Pagliuca",
      "Bobbi Sternheim",
      "Ghislaine Maxwell",
      "Jeffrey Epstein",
      "Nathan"
    ],
    "organizations": [
      "U.S Department of Justice",
      "United States Attorney",
      "Cohen & Gresser LLP",
      "Haddon, Morgan and Foreman, P.C.",
      "Law Offices of Bobbi C. Sternheim"
    ],
    "locations": [
      "New York",
      "Denver",
      "Southern District of New York"
    ],
    "dates": [
      "October 11, 2021",
      "September 3, 2021",
      "10/29/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "384-1",
      "20 Cr. 330 (AJN)",
      "Dkt. No. 335",
      "DOJ-OGR-00005608"
    ]
  },
  "additional_notes": "The document appears to be a letter from the U.S. Department of Justice to counsel regarding the case United States v. Ghislaine Maxwell. The letter is dated October 11, 2021, and references a court order from September 3, 2021. The document is printed and contains no handwritten text or stamps."
}