{
  "document_metadata": {
    "page_number": "1",
    "document_number": "38",
    "date": "08/10/20",
    "document_type": "Court Document",
    "has_handwriting": true,
    "has_stamps": true
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 38 Filed 08/10/20 Page 1 of 6 COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 +1 212 957 7600 www.cohengresser.com Mark S. Cohen +1 (212) 957-7600 mcohen@cohengresser.com Christian R. Everdell +1 (212) 957-7600 ceverdell@cohengresser.com August 10, 2020 VIA ECF The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: On behalf of our client, Ghislaine Maxwell, we respectfully submit this letter motion seeking the Court's assistance with two critical issues that greatly impact Ms. Maxwell's ability to receive a fair trial on the schedule set by the Court. First, we request that the Court enter an order directing the government to disclose to defense counsel the identities of the three alleged victims referenced in the indictment (\"Victims 1-3\"), subject to the restrictions of the protective order entered by the Court, so that Ms. Maxwell and defense counsel can meaningfully investigate the alleged conduct, which is now over 25 years old. Second, we request that the Court enter an order directing the Bureau of Prisons (\"BOP\") to release Ms. Maxwell into the general population and provide Ms. Maxwell with increased access to the discovery materials while she is detained so that she can meaningfully participate in the preparation of her defense. 1. Disclosure of Victim Identities The Court should order the government to disclose the identities of Victims 1-3 to defense counsel, subject to the restrictions of the protective order, because Ms. Maxwell cannot prepare for or receive a fair trial without this information. Moreover, the requested disclosure is authorized under the law in this Circuit, and is narrowly-tailored and reasonable under the circumstances of this case. Here, it is clear from the face of the indictment that the government's case is based on the accounts of Victims 1-3, the three individuals specifically referenced in the indictment. It is therefore critical for the defense to know the names of these individuals as soon as possible, so The Government is hereby ORDERED to respond to the Defendant's letter motion by Thursday, August 13, 2020. The Defendant's reply, if any, is due on or before Monday, August 17, 2020. SO ORDERED. Alison J. Nathan, U.S.D.J. SO ORDERED. 8/11/20 DOJ-OGR-00001713",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 38 Filed 08/10/20 Page 1 of 6",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 +1 212 957 7600 www.cohengresser.com",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Mark S. Cohen +1 (212) 957-7600 mcohen@cohengresser.com Christian R. Everdell +1 (212) 957-7600 ceverdell@cohengresser.com",
      "position": "header"
    },
    {
      "type": "stamp",
      "content": "USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC #: DATE FILED: 8/11/20",
      "position": "margin"
    },
    {
      "type": "printed",
      "content": "August 10, 2020 VIA ECF The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan:",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "On behalf of our client, Ghislaine Maxwell, we respectfully submit this letter motion seeking the Court's assistance with two critical issues that greatly impact Ms. Maxwell's ability to receive a fair trial on the schedule set by the Court. First, we request that the Court enter an order directing the government to disclose to defense counsel the identities of the three alleged victims referenced in the indictment (\"Victims 1-3\"), subject to the restrictions of the protective order entered by the Court, so that Ms. Maxwell and defense counsel can meaningfully investigate the alleged conduct, which is now over 25 years old. Second, we request that the Court enter an order directing the Bureau of Prisons (\"BOP\") to release Ms. Maxwell into the general population and provide Ms. Maxwell with increased access to the discovery materials while she is detained so that she can meaningfully participate in the preparation of her defense.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "1. Disclosure of Victim Identities The Court should order the government to disclose the identities of Victims 1-3 to defense counsel, subject to the restrictions of the protective order, because Ms. Maxwell cannot prepare for or receive a fair trial without this information. Moreover, the requested disclosure is authorized under the law in this Circuit, and is narrowly-tailored and reasonable under the circumstances of this case. Here, it is clear from the face of the indictment that the government's case is based on the accounts of Victims 1-3, the three individuals specifically referenced in the indictment. It is therefore critical for the defense to know the names of these individuals as soon as possible, so",
      "position": "middle"
    },
    {
      "type": "handwritten",
      "content": "SO ORDERED. 8/11/20",
      "position": "margin"
    },
    {
      "type": "printed",
      "content": "The Government is hereby ORDERED to respond to the Defendant's letter motion by Thursday, August 13, 2020. The Defendant's reply, if any, is due on or before Monday, August 17, 2020. SO ORDERED.",
      "position": "margin"
    },
    {
      "type": "signature",
      "content": "Alison J. Nathan, U.S.D.J.",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00001713",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Mark S. Cohen",
      "Christian R. Everdell",
      "Alison J. Nathan",
      "Ghislaine Maxwell"
    ],
    "organizations": [
      "COHEN & GRESSER LLP",
      "United States District Court",
      "Southern District of New York",
      "Bureau of Prisons"
    ],
    "locations": [
      "New York",
      "United States"
    ],
    "dates": [
      "August 10, 2020",
      "August 13, 2020",
      "August 17, 2020",
      "8/11/20"
    ],
    "reference_numbers": [
      "Case 1:20-cr-00330-AJN",
      "Document 38",
      "20 Cr. 330 (AJN)",
      "DOJ-OGR-00001713"
    ]
  },
  "additional_notes": "The document appears to be a court filing in the case United States v. Ghislaine Maxwell. It is a letter motion submitted by the defense counsel, COHEN & GRESSER LLP, requesting the court to order the government to disclose the identities of the alleged victims and to release Ghislaine Maxwell into the general population. The document is stamped as electronically filed and includes a handwritten order from the judge."
}