{
  "document_metadata": {
    "page_number": "1",
    "document_number": "42",
    "date": "08/17/20",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 42 Filed 08/17/20 Page 1 of 5 COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 +1 212 957 7600 phone www.cohengresser.com Mark S. Cohen +1 (212) 957-7600 mcohen@cohengresser.com Christian R. Everdell +1 (212) 957-7600 ceverdell@cohengresser.com August 17, 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 to reply to the government's letter, dated August 13, 2020, responding to Ms. Maxwell's request that the Court (i) direct the government to disclose the identities of the three alleged victims referenced in the indictment, subject to the restrictions of the protective order in this case; and (ii) order the Bureau of Prisons (\"BOP\") to provide Ms. Maxwell with increased access to the discovery materials (\"Government's Response\" or \"Gov't Resp.\") (Dkt. 41). With regard to the issue of alleged victims' identities, the government concedes, as it must, that this Court has the authority and discretion to order the relief sought, but claims that Ms. Maxwell's application should be denied as untimely and without merit. (Gov't Resp. at 2-4). Instead, the government asserts that the appropriate and timely way for Ms. Maxwell to seek confirmation of their identities is through a request for a bill of particulars, which should be filed in December 2020. (Id. at 3). The government then notes that it would oppose such a motion, which it claims should also be denied. (Id.). The government concludes that it will finally provide confirmation of their identities in the 3500 material and a witness list to be provided shortly before trial. (Id. at 4). The upshot of this is clear: in the government's view, Ms. Maxwell should not know the identity of the three witnesses referenced in the indictment until at best just before trial, and should have to spend the next eleven months (or longer) trying to conduct a defense investigation, in a case in which she is presumed innocent, without having this information. This information is critical to conducting a meaningful defense investigation, given that the DOJ-OGR-00001724",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 42 Filed 08/17/20 Page 1 of 5",
      "position": "header"
    },
    {
      "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": "Mark S. Cohen +1 (212) 957-7600 mcohen@cohengresser.com Christian R. Everdell +1 (212) 957-7600 ceverdell@cohengresser.com",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "August 17, 2020",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "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",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Dear Judge Nathan: On behalf of our client, Ghislaine Maxwell, we respectfully submit this letter to reply to the government's letter, dated August 13, 2020, responding to Ms. Maxwell's request that the Court (i) direct the government to disclose the identities of the three alleged victims referenced in the indictment, subject to the restrictions of the protective order in this case; and (ii) order the Bureau of Prisons (\"BOP\") to provide Ms. Maxwell with increased access to the discovery materials (\"Government's Response\" or \"Gov't Resp.\") (Dkt. 41).",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "With regard to the issue of alleged victims' identities, the government concedes, as it must, that this Court has the authority and discretion to order the relief sought, but claims that Ms. Maxwell's application should be denied as untimely and without merit. (Gov't Resp. at 2-4). Instead, the government asserts that the appropriate and timely way for Ms. Maxwell to seek confirmation of their identities is through a request for a bill of particulars, which should be filed in December 2020. (Id. at 3). The government then notes that it would oppose such a motion, which it claims should also be denied. (Id.). The government concludes that it will finally provide confirmation of their identities in the 3500 material and a witness list to be provided shortly before trial. (Id. at 4).",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The upshot of this is clear: in the government's view, Ms. Maxwell should not know the identity of the three witnesses referenced in the indictment until at best just before trial, and should have to spend the next eleven months (or longer) trying to conduct a defense investigation, in a case in which she is presumed innocent, without having this information. This information is critical to conducting a meaningful defense investigation, given that the",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00001724",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Mark S. Cohen",
      "Christian R. Everdell",
      "Alison J. Nathan",
      "Ghislaine Maxwell"
    ],
    "organizations": [
      "COHEN & GRESSER LLP",
      "United States District Court",
      "Bureau of Prisons"
    ],
    "locations": [
      "New York",
      "Southern District of New York",
      "United States"
    ],
    "dates": [
      "August 17, 2020",
      "August 13, 2020",
      "December 2020"
    ],
    "reference_numbers": [
      "Case 1:20-cr-00330-AJN",
      "Document 42",
      "20 Cr. 330 (AJN)",
      "Dkt. 41"
    ]
  },
  "additional_notes": "The document appears to be a formal letter from COHEN & GRESSER LLP to the Honorable Alison J. Nathan, regarding the case United States v. Ghislaine Maxwell. The letter is typed and has a professional tone. There are no visible redactions or damage to the document."
}