{
  "document_metadata": {
    "page_number": "4",
    "document_number": "314",
    "date": "07/12/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 314 Filed 07/12/21 Page 4 of 7\nPage 4\nwritten agreement, as opposed to an informal promise like the one in Cosby.\nThis is not consistent with principles of fundamental fairness.\n(emphasis added).\nThe press (including Bloomberg, NBC, the New York Post, and Forbes)4 reported on this argument by Ms. Maxwell's lawyers. Accordingly, there is no substantial likelihood that the Op-Ed, which made the very same arguments that were made by Ms. Maxwell's lawyers and covered extensively in the press, will interfere with a fair trial, and the Government does not even really attempt to argue to the contrary.5\nSecond, Ms. Maxwell's family, and undersigned as counsel for her family, have the right to respond to the numerous lawyers, witnesses, and surrogates who are speaking to the press and making it impossible for Ms. Maxwell to receive a fair trial. As Justice Kennedy explained in Gentile, “in some circumstances press comment is necessary to protect the rights of the client and prevent abuse.” Such “statements have the full protection of the First Amendment.” Gentile, 501 U.S. at 1058 (Kennedy, J., concurring).\nThe press has been unrelenting and overwhelmingly prejudicial in its coverage of Ms. Maxwell and her family, fueled by statements from involved parties about the matters at issue. It is not an understatement to say that 99.9% of the press coverage is pro-government and anti-Maxwell. The press has already tried and convicted her. the problem worse. How can Ms. Maxwell be expected to receive a fair trial when lawyers for the accusers are holding press conferences, leaking information, and\n4 See, e.g., https://www.bloomberg.com/news/articles/2021-07-02/ghislaine-maxwell-says-cosby-ruling-should-end-her-abuse-case; https://www.nbcnews.com/news/ghislainemaxwell-s-lawyers-cite-cosby-case-bid-have-sex-n1273037; https://nypost.com/2021/07/02/ghislaine-maxwell-should-be-sprung-from-prison-just-like-bill-cosby-lawyers/; and https://www.forbes.com/sites/joewalsh/2021/07/02/ghislaine-maxwell-tells-judge-hercase-should-be-tossed-out-like-cosbys/?sh=68a89d9578bc\n5 The Government also complains that the Op-Ed described the accusations as “stale” and “flimsy.” But both descriptions have been used in publicly filed pleadings. Moreover, many of the accusations are in fact decades old, and similar descriptive words have been held not to violate the rules. See, e.g., Law360, Brooklyn U.S. Attorney's Pretrial Remarks Fair Game, Judge Says, July 1, 2021 (reporting that Judge Dora Irizarry held that U.S. Attorney's comments that defendant had engaged in a “spree” of robberies that were “unprecedented” did not violate the local rule and also did not prejudice the defendant), story available at: https://tinyurl.com/4bnu2kfz\nDOJ-OGR-00004958",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 314 Filed 07/12/21 Page 4 of 7",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Page 4",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "written agreement, as opposed to an informal promise like the one in Cosby.\nThis is not consistent with principles of fundamental fairness.\n(emphasis added).",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The press (including Bloomberg, NBC, the New York Post, and Forbes)4 reported on this argument by Ms. Maxwell's lawyers. Accordingly, there is no substantial likelihood that the Op-Ed, which made the very same arguments that were made by Ms. Maxwell's lawyers and covered extensively in the press, will interfere with a fair trial, and the Government does not even really attempt to argue to the contrary.5",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Second, Ms. Maxwell's family, and undersigned as counsel for her family, have the right to respond to the numerous lawyers, witnesses, and surrogates who are speaking to the press and making it impossible for Ms. Maxwell to receive a fair trial. As Justice Kennedy explained in Gentile, “in some circumstances press comment is necessary to protect the rights of the client and prevent abuse.” Such “statements have the full protection of the First Amendment.” Gentile, 501 U.S. at 1058 (Kennedy, J., concurring).",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The press has been unrelenting and overwhelmingly prejudicial in its coverage of Ms. Maxwell and her family, fueled by statements from involved parties about the matters at issue. It is not an understatement to say that 99.9% of the press coverage is pro-government and anti-Maxwell. The press has already tried and convicted her. the problem worse. How can Ms. Maxwell be expected to receive a fair trial when lawyers for the accusers are holding press conferences, leaking information, and",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "4 See, e.g., https://www.bloomberg.com/news/articles/2021-07-02/ghislaine-maxwell-says-cosby-ruling-should-end-her-abuse-case; https://www.nbcnews.com/news/ghislainemaxwell-s-lawyers-cite-cosby-case-bid-have-sex-n1273037; https://nypost.com/2021/07/02/ghislaine-maxwell-should-be-sprung-from-prison-just-like-bill-cosby-lawyers/; and https://www.forbes.com/sites/joewalsh/2021/07/02/ghislaine-maxwell-tells-judge-hercase-should-be-tossed-out-like-cosbys/?sh=68a89d9578bc",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "5 The Government also complains that the Op-Ed described the accusations as “stale” and “flimsy.” But both descriptions have been used in publicly filed pleadings. Moreover, many of the accusations are in fact decades old, and similar descriptive words have been held not to violate the rules. See, e.g., Law360, Brooklyn U.S. Attorney's Pretrial Remarks Fair Game, Judge Says, July 1, 2021 (reporting that Judge Dora Irizarry held that U.S. Attorney's comments that defendant had engaged in a “spree” of robberies that were “unprecedented” did not violate the local rule and also did not prejudice the defendant), story available at: https://tinyurl.com/4bnu2kfz",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00004958",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Ms. Maxwell",
      "Justice Kennedy",
      "Bill Cosby",
      "Dora Irizarry",
      "Ghislaine Maxwell"
    ],
    "organizations": [
      "Bloomberg",
      "NBC",
      "New York Post",
      "Forbes",
      "Law360",
      "Brooklyn U.S. Attorney"
    ],
    "locations": [
      "New York"
    ],
    "dates": [
      "07/12/21",
      "July 1, 2021",
      "2021-07-02"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 314",
      "DOJ-OGR-00004958",
      "501 U.S. at 1058"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Ghislaine Maxwell. The text is printed and there are no visible stamps or handwritten notes. The document is page 4 of a 7-page document."
}