{
  "document_metadata": {
    "page_number": "3 of 3",
    "document_number": "313",
    "date": "07/09/21",
    "document_type": "Court Document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 313 Filed 07/09/21 Page 3 of 3\nLAW OFFICES OF BOBBI C. STERNHEIM\nrepresenting any party or witness to the case. Their position on the applicability of Rule 23.1 apparently fluctuates depending on who is talking to the press.\nAccordingly, we would ask the Court to be mindful of two important points. First, Ms. Maxwell has been, and continues to be, the subject of an unquestionable tsunami of adverse publicity every day, which is surely impacting the pool of jurors in the Southern District of New York. Second, efforts to persuade the public and the government that a defendant should not be prosecuted are permissible. See Gentile v. State Bar of Nevada, 501 U.S. 1030, 1043 (1991) (“A defense attorney may pursue lawful strategies to obtain dismissal of an indictment or reduction of charges, including an attempt to demonstrate in the court of public opinion that the client does not deserve to be tried.”).\nRespectfully submitted:\n/s/ Bobbi C. Sternheim\n/s/ Christian R. Everdell\n/s/ Laura A. Menninger\n/s/ Jeffrey S. Pagliuca\ncc: Government counsel\nDavid Oscar Markus, Esq.\n3\nDOJ-OGR-00004954",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 313 Filed 07/09/21 Page 3 of 3",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "LAW OFFICES OF BOBBI C. STERNHEIM",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "representing any party or witness to the case. Their position on the applicability of Rule 23.1 apparently fluctuates depending on who is talking to the press.\nAccordingly, we would ask the Court to be mindful of two important points. First, Ms. Maxwell has been, and continues to be, the subject of an unquestionable tsunami of adverse publicity every day, which is surely impacting the pool of jurors in the Southern District of New York. Second, efforts to persuade the public and the government that a defendant should not be prosecuted are permissible. See Gentile v. State Bar of Nevada, 501 U.S. 1030, 1043 (1991) (“A defense attorney may pursue lawful strategies to obtain dismissal of an indictment or reduction of charges, including an attempt to demonstrate in the court of public opinion that the client does not deserve to be tried.”).",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "Respectfully submitted:\n/s/ Bobbi C. Sternheim\n/s/ Christian R. Everdell\n/s/ Laura A. Menninger\n/s/ Jeffrey S. Pagliuca",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "cc: Government counsel\nDavid Oscar Markus, Esq.",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "3",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00004954",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Bobbi C. Sternheim",
      "Christian R. Everdell",
      "Laura A. Menninger",
      "Jeffrey S. Pagliuca",
      "David Oscar Markus",
      "Maxwell"
    ],
    "organizations": [
      "State Bar of Nevada",
      "LAW OFFICES OF BOBBI C. STERNHEIM"
    ],
    "locations": [
      "New York",
      "Southern District of New York"
    ],
    "dates": [
      "07/09/21",
      "1991"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "313",
      "501 U.S. 1030",
      "DOJ-OGR-00004954"
    ]
  },
  "additional_notes": "The document appears to be a court filing from the Law Offices of Bobbi C. Sternheim, discussing the case of Ms. Maxwell and referencing a legal precedent from the U.S. Supreme Court case Gentile v. State Bar of Nevada (1991)."
}