{
  "document_metadata": {
    "page_number": "1",
    "document_number": "358",
    "date": "October 18, 2021",
    "document_type": "Court Document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 358 Filed 10/18/21 Page 1 of 4 Haddon, Morgan and Foreman, P.C Jeffrey Pagliuca HADDON MORGAN FOREMAN 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 FX 303.832.2628 www.hmflaw.com jpagliuca@hmflaw.com October 18, 2021 VIA ECF The Honorable Alison J. Nathan United States District Court Southern District of New York 40 Foley Square New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: Today, counsel for Ghislaine Maxwell filed 13 motions in limine and accompanying exhibits seeking the following relief: to Preclude the Introduction of Alleged Co-Conspirator Statements as a Sanction for Failing to Comply with This Court's September 3, 2021 Order; to Exclude Any Evidence Offered by the Government Pursuant to Fed. R. Evid. 404(b) for Failure to Comply with the Rule's Notice Requirement; to Exclude Under Federal Rule of Evidence 702 and Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 (1993) and Request for Daubert Hearing; to Exclude Evidence Related to Accuser-3; to Exclude Evidence of Alleged Flight; to Exclude Evidence of Ms. Maxwell's Alleged False Statements and to Redact Allegations Related to the Perjury Counts from the Second Superseding Indictment; DOJ-OGR-00005260",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 358 Filed 10/18/21 Page 1 of 4",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Haddon, Morgan and Foreman, P.C Jeffrey Pagliuca HADDON MORGAN FOREMAN 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 FX 303.832.2628 www.hmflaw.com jpagliuca@hmflaw.com",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "October 18, 2021 VIA ECF The Honorable Alison J. Nathan United States District Court Southern District of New York 40 Foley Square New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: Today, counsel for Ghislaine Maxwell filed 13 motions in limine and accompanying exhibits seeking the following relief: to Preclude the Introduction of Alleged Co-Conspirator Statements as a Sanction for Failing to Comply with This Court's September 3, 2021 Order; to Exclude Any Evidence Offered by the Government Pursuant to Fed. R. Evid. 404(b) for Failure to Comply with the Rule's Notice Requirement; to Exclude Under Federal Rule of Evidence 702 and Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 (1993) and Request for Daubert Hearing; to Exclude Evidence Related to Accuser-3; to Exclude Evidence of Alleged Flight; to Exclude Evidence of Ms. Maxwell's Alleged False Statements and to Redact Allegations Related to the Perjury Counts from the Second Superseding Indictment;",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00005260",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ghislaine Maxwell",
      "Jeffrey Pagliuca"
    ],
    "organizations": [
      "Haddon, Morgan and Foreman, P.C",
      "United States District Court",
      "Southern District of New York"
    ],
    "locations": [
      "Denver",
      "Colorado",
      "New York"
    ],
    "dates": [
      "October 18, 2021",
      "September 3, 2021"
    ],
    "reference_numbers": [
      "20 Cr. 330 (AJN)",
      "DOJ-OGR-00005260",
      "Document 358"
    ]
  },
  "additional_notes": "The document appears to be a court filing in the case United States v. Ghislaine Maxwell. It is a formal letter to Judge Alison J. Nathan from Jeffrey Pagliuca of Haddon, Morgan and Foreman, P.C. The document is well-formatted and free of significant damage or redactions."
}