{
  "document_metadata": {
    "page_number": "1",
    "document_number": "547",
    "date": "December 15, 2021",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 547 Filed 12/15/21 Page 1 of 2\nLAW OFFICES OF BOBBI C. STERNHEIM\n212-243-1100 · Main\n917-912-9698 · Cell\n888-587-4737 · Fax\n225 Broadway, Suite 715\nNew York, NY 10007\nbcsternheim@mac.com\nDecember 15, 2021\nHonorable Alison J. Nathan\nUnited States District Judge\nUnited States Courthouse\n40 Foley Square\nNew York, NY 10007\nRe: United States v. Ghislaine Maxwell\nS2 20 Cr. 330 (AJN)\nDear Judge Nathan:\nThe government's limitation on Dr. Loftus's testimony is a desperate attempt to restrict relevant testimony. Accusers were asked suggestive questions during interviews and prep sessions with the government. We anticipate that Agent Young will be testifying about the form of questions asked during such interviews and prep sessions. A review of the 3500 material and Jane's testimony exemplify the type of questioning the government posited during their investigation.\nBy way of example, during cross examination, Jane was asked about the government's repeated questioning regarding whether sexual abuse occurred in New Mexico, during two separate interviews and, during one of those interviews, three separate times. TR 512-516. Also, the government challenged Jane's recollection that she had seen The Lion King on Broadway during her first trip to New York at age 14, outright suggesting that she saw the movie instead. When Jane's counsel confirmed that she had seen the Broadway show, not the movie, AUSA Rossmiller told her lawyer that the government would just \"assume\" that The Lion King trip was not her first trip to New York, even though that is what Jane had reported to them. TR. 503-511; see 3509-010. True to form, at her very next call with the government a few weeks later, she followed their lead and \"remembered\" that the Lion King trip had not been her first trip to New York. See 3509-011.\nDOJ-OGR-00008385",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 547 Filed 12/15/21 Page 1 of 2",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "LAW OFFICES OF BOBBI C. STERNHEIM",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "212-243-1100 · Main\n917-912-9698 · Cell\n888-587-4737 · Fax\n225 Broadway, Suite 715\nNew York, NY 10007\nbcsternheim@mac.com",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "December 15, 2021",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Honorable Alison J. Nathan\nUnited States District Judge\nUnited States Courthouse\n40 Foley Square\nNew York, NY 10007",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Re: United States v. Ghislaine Maxwell\nS2 20 Cr. 330 (AJN)",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Dear Judge Nathan:",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The government's limitation on Dr. Loftus's testimony is a desperate attempt to restrict relevant testimony. Accusers were asked suggestive questions during interviews and prep sessions with the government. We anticipate that Agent Young will be testifying about the form of questions asked during such interviews and prep sessions. A review of the 3500 material and Jane's testimony exemplify the type of questioning the government posited during their investigation.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "By way of example, during cross examination, Jane was asked about the government's repeated questioning regarding whether sexual abuse occurred in New Mexico, during two separate interviews and, during one of those interviews, three separate times. TR 512-516. Also, the government challenged Jane's recollection that she had seen The Lion King on Broadway during her first trip to New York at age 14, outright suggesting that she saw the movie instead. When Jane's counsel confirmed that she had seen the Broadway show, not the movie, AUSA Rossmiller told her lawyer that the government would just \"assume\" that The Lion King trip was not her first trip to New York, even though that is what Jane had reported to them. TR. 503-511; see 3509-010. True to form, at her very next call with the government a few weeks later, she followed their lead and \"remembered\" that the Lion King trip had not been her first trip to New York. See 3509-011.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00008385",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ghislaine Maxwell",
      "Dr. Loftus",
      "Agent Young",
      "Jane",
      "AUSA Rossmiller",
      "Bobbi C. Sternheim"
    ],
    "organizations": [
      "Law Offices of Bobbi C. Sternheim",
      "United States District Court"
    ],
    "locations": [
      "New York",
      "New Mexico",
      "Broadway"
    ],
    "dates": [
      "December 15, 2021"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "547",
      "S2 20 Cr. 330 (AJN)",
      "TR 512-516",
      "TR. 503-511",
      "3509-010",
      "3509-011",
      "DOJ-OGR-00008385"
    ]
  },
  "additional_notes": "The document appears to be a letter from Bobbi C. Sternheim to Honorable Alison J. Nathan regarding the case United States v. Ghislaine Maxwell. The letter discusses the government's limitation on Dr. Loftus's testimony and the suggestive questions asked during interviews and prep sessions with the government."
}