{
  "document_metadata": {
    "page_number": "1",
    "document_number": "239",
    "date": "04/23/21",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 239 Filed 04/23/21 Page 1 of 6\nU.S. Department of Justice\nUnited States Attorney\nSouthern District of New York\nThe Silvio J. Mollo Building\nOne Saint Andrew's Plaza\nNew York, New York 10007\nApril 23, 2021\nBY ECF\nThe Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\nUnited States Courthouse\n40 Foley Square\nNew York, New York 10007\nRe: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)\nDear Judge Nathan:\nThe Government respectfully submits this letter in response to the Court's Order dated April 16, 2021, which directed the Government to confirm that it has complied with its discovery obligations with respect to the non-prosecution agreement (\"NPA\") between Jeffrey Epstein and the U.S. Attorney's Office for the Southern District of Florida (\"SDFL\"). (Dkt. No. 207).\nA. Overview\nThe Government takes its discovery and disclosure obligations seriously, and it has endeavored to take an expansive approach with respect to those obligations throughout the pendency of this case. In particular, the Government carefully formulated its discovery and disclosure plan in this case to ensure that it not only satisfies its Rule 16, Brady, Giglio, and Jencks Act obligations with respect to the materials already in the possession of the prosecution team, but that it also makes reasonable efforts to identify other potentially disclosable material within the files of other investigative agencies who are not part of this prosecution team. This approach was formulated in close consultation with multiple layers of supervisors within the U.S. Attorney's Office for the Southern District of New York. The Government set forth its intentions with respect\nDOJ-OGR-00003955",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 239 Filed 04/23/21 Page 1 of 6",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "U.S. Department of Justice\nUnited States Attorney\nSouthern District of New York\nThe Silvio J. Mollo Building\nOne Saint Andrew's Plaza\nNew York, New York 10007",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "April 23, 2021",
      "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, New York 10007",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Dear Judge Nathan:\nThe Government respectfully submits this letter in response to the Court's Order dated April 16, 2021, which directed the Government to confirm that it has complied with its discovery obligations with respect to the non-prosecution agreement (\"NPA\") between Jeffrey Epstein and the U.S. Attorney's Office for the Southern District of Florida (\"SDFL\"). (Dkt. No. 207).",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "A. Overview\nThe Government takes its discovery and disclosure obligations seriously, and it has endeavored to take an expansive approach with respect to those obligations throughout the pendency of this case. In particular, the Government carefully formulated its discovery and disclosure plan in this case to ensure that it not only satisfies its Rule 16, Brady, Giglio, and Jencks Act obligations with respect to the materials already in the possession of the prosecution team, but that it also makes reasonable efforts to identify other potentially disclosable material within the files of other investigative agencies who are not part of this prosecution team. This approach was formulated in close consultation with multiple layers of supervisors within the U.S. Attorney's Office for the Southern District of New York. The Government set forth its intentions with respect",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00003955",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ghislaine Maxwell",
      "Jeffrey Epstein"
    ],
    "organizations": [
      "U.S. Department of Justice",
      "United States Attorney",
      "U.S. Attorney's Office for the Southern District of Florida",
      "U.S. Attorney's Office for the Southern District of New York"
    ],
    "locations": [
      "New York",
      "Florida"
    ],
    "dates": [
      "April 23, 2021",
      "April 16, 2021"
    ],
    "reference_numbers": [
      "20 Cr. 330 (AJN)",
      "Dkt. No. 207",
      "DOJ-OGR-00003955"
    ]
  },
  "additional_notes": "The document appears to be a formal letter from the U.S. Department of Justice to the Honorable Alison J. Nathan regarding the case United States v. Ghislaine Maxwell. The document is well-formatted and free of handwritten text or stamps."
}