{
  "document_metadata": {
    "page_number": "1",
    "document_number": "163",
    "date": "03/01/2021",
    "document_type": "Court Document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 163 Filed 03/01/21 Page 1 of 2\nCOHEN & GRESSER LLP\n800 Third Avenue New York, NY 10022 +1 212 957 7600 phone www.cohengresser.com\nChristian R. Everdell +1 (212) 957-7600 ceverdell@cohengresser.com\nMarch 1, 2021\nBY ECF\nThe Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New 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 10-day extension of time until Monday, March 15, 2021 to file our reply to the Government's Omnibus Memorandum in Opposition to the Defendant's Pre-trial Motions. We have conferred with the government, which has consented to the requested extension.\nThe requested extension is necessary because the government filed a lengthy response that included multiple exhibits and produced additional discovery that pertains to the motion response, all of which we will need time to review, analyze and discuss with our client. It will take several days for Ms. Maxwell to receive copies of these materials in the MDC. It will not be feasible for her to receive and review these lengthy materials, discuss them with counsel, and then read and provide comments on the draft replies in a week's time.\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 revised briefing schedule, the defendant's pretrial motions were due on January 11, 2020, the government's response was due February 12, 2021, and the defendant's reply was due on February 19, 2021. (Id.). On January 5, 2021, at the defense's request and with the consent of the government, the Court agreed to modify the briefing schedule and set the current deadlines: the defendant's pretrial motions were due on January 25, 2021, the government's response was due February 26, 2021, and the defendant's reply is due on March 5, 2021. (Dkt. 108).\nDOJ-OGR-00002744",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 163 Filed 03/01/21 Page 1 of 2",
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    {
      "type": "printed",
      "content": "COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 +1 212 957 7600 phone www.cohengresser.com",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Christian R. Everdell +1 (212) 957-7600 ceverdell@cohengresser.com",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "March 1, 2021",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "BY ECF The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square 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 Judge Nathan: We write on behalf of our client, Ghislaine Maxwell, to respectfully request a 10-day extension of time until Monday, March 15, 2021 to file our reply to the Government's Omnibus Memorandum in Opposition to the Defendant's Pre-trial Motions. We have conferred with the government, which has consented to the requested extension.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The requested extension is necessary because the government filed a lengthy response that included multiple exhibits and produced additional discovery that pertains to the motion response, all of which we will need time to review, analyze and discuss with our client. It will take several days for Ms. Maxwell to receive copies of these materials in the MDC. It will not be feasible for her to receive and review these lengthy materials, discuss them with counsel, and then read and provide comments on the draft replies in a week's time.",
      "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 revised briefing schedule, the defendant's pretrial motions were due on January 11, 2020, the government's response was due February 12, 2021, and the defendant's reply was due on February 19, 2021. (Id.). On January 5, 2021, at the defense's request and with the consent of the government, the Court agreed to modify the briefing schedule and set the current deadlines: the defendant's pretrial motions were due on January 25, 2021, the government's response was due February 26, 2021, and the defendant's reply is due on March 5, 2021. (Dkt. 108).",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00002744",
      "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"
    ],
    "dates": [
      "March 1, 2021",
      "March 15, 2021",
      "December 21, 2020",
      "January 22, 2021",
      "February 5, 2021",
      "January 11, 2020",
      "February 12, 2021",
      "February 19, 2021",
      "January 5, 2021",
      "January 25, 2021",
      "February 26, 2021",
      "March 5, 2021"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "Document 163",
      "20 Cr. 330 (AJN)",
      "Dkt. 25",
      "Dkt. 72",
      "Dkt. 108"
    ]
  },
  "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 10-day extension to file a reply to the Government's Omnibus Memorandum in Opposition to the Defendant's Pre-trial Motions. The document is well-formatted and free of significant damage or redactions."
}