{
  "document_metadata": {
    "page_number": "13",
    "document_number": "246",
    "date": "04/23/2021",
    "document_type": "court document",
    "has_handwriting": true,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 246 Filed 04/23/21 Page 13 of 13 The Hon. Alison J. Nathan April 22, 2021 Page 13 Like the Court, I fully recognize that a superseding indictment may add to a defendant's burden in preparing for trial. In the event of additional charges or material changes, a defendant then may need additional preparation time. Under the Act a defendant may seek an \"ends of justice\" continuance, to be granted in the discretion of the trial court. See 18 U.S.C. 3161(h)(8)(A). This continuance is available whether the need for additional time is occasioned by a superseding indictment or otherwise. Indeed, the 1979 amendments to the Speedy Trial Act not only mandated the 30-day defense-preparation period, but also provided that one basis for granting a continuance is \"if the failure to grant such a continuance . . . would deny counsel for the defendant . . . the reasonable time necessary for effective preparation . . .\" 18 U.S.C. 3161(h)(8)(B)(iv). The constitutional right to assistance of counsel is rendered meaningless if a defendant is forced to trial in the absence of adequate time to prepare. To avoid prejudicing a defendant, a continuance should be granted where there is a meaningful possibility that a superseding indictment will require an alteration or adjustment in the planned defense. Trial courts should bear in mind that counsel may require time fully to analyze the impact of the superseding indictment, and to explore any options it presents or precludes. Id. at 240-41. Based on the foregoing and consistent with the holding in United States v. Guzman, Ms. Maxwell hereby specifically requests a 120-day continuance of her trial to November 8, 2021, contingent upon the re-scheduling of the trial before Judge Furman. In the alternative, she requests a 180-day continuance to January 10, 2022. Respectfully submitted, Laura A. Menninger CC: Counsel of Record DOJ-OGR-00004000",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 246 Filed 04/23/21 Page 13 of 13",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "The Hon. Alison J. Nathan April 22, 2021 Page 13",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Like the Court, I fully recognize that a superseding indictment may add to a defendant's burden in preparing for trial. In the event of additional charges or material changes, a defendant then may need additional preparation time. Under the Act a defendant may seek an \"ends of justice\" continuance, to be granted in the discretion of the trial court. See 18 U.S.C. 3161(h)(8)(A). This continuance is available whether the need for additional time is occasioned by a superseding indictment or otherwise. Indeed, the 1979 amendments to the Speedy Trial Act not only mandated the 30-day defense-preparation period, but also provided that one basis for granting a continuance is \"if the failure to grant such a continuance . . . would deny counsel for the defendant . . . the reasonable time necessary for effective preparation . . .\" 18 U.S.C. 3161(h)(8)(B)(iv). The constitutional right to assistance of counsel is rendered meaningless if a defendant is forced to trial in the absence of adequate time to prepare. To avoid prejudicing a defendant, a continuance should be granted where there is a meaningful possibility that a superseding indictment will require an alteration or adjustment in the planned defense. Trial courts should bear in mind that counsel may require time fully to analyze the impact of the superseding indictment, and to explore any options it presents or precludes.",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "Id. at 240-41.",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "Based on the foregoing and consistent with the holding in United States v. Guzman, Ms. Maxwell hereby specifically requests a 120-day continuance of her trial to November 8, 2021, contingent upon the re-scheduling of the trial before Judge Furman. In the alternative, she requests a 180-day continuance to January 10, 2022.",
      "position": "main"
    },
    {
      "type": "handwritten",
      "content": "Respectfully submitted,",
      "position": "main"
    },
    {
      "type": "handwritten",
      "content": "Laura A. Menninger",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "CC: Counsel of Record",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00004000",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Guzman",
      "Maxwell",
      "Furman",
      "Laura A. Menninger"
    ],
    "organizations": [],
    "locations": [],
    "dates": [
      "April 22, 2021",
      "November 8, 2021",
      "January 10, 2022",
      "04/23/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 246",
      "DOJ-OGR-00004000"
    ]
  },
  "additional_notes": "The document appears to be a court filing with a mix of printed and handwritten text. The handwritten text is likely a signature. The document is well-formatted and legible."
}