mirror-epstein-docs/results/IMAGES001/DOJ-OGR-00001497.json

{
  "document_metadata": {
    "page_number": "1",
    "document_number": "5",
    "date": "07/05/20",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 5 Filed 07/05/20 Page 1 of 2\nU.S. Department of Justice\nUnited States Attorney\nSouthern District of New York\nThe Silvio J. Mollo Building\nOne Saint Andrew's Plaza\nNew York, New York 10007\nJuly 5, 2020\n\nVIA ECF\nThe Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\nUnited States Courthouse\n40 Foley Square\nNew York, New York 10007\n\nRe: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)\n\nDear Judge Nathan:\n\nThe Government respectfully submits this letter to request that the Court schedule an arraignment, initial appearance, and bail hearing in the above referenced case. On July 2, 2020, the defendant was arrested in Bradford, New Hampshire on the charges contained in the above-captioned Indictment and presented before a United States Magistrate Judge in the District of New Hampshire. At that appearance, the defendant waived her right to an identity hearing, consented to detention without prejudice to making a later application for bail, and consented to her transfer to the Southern District of New York.\n\nWhile the Government has no control over the timing of the defendant's transport, the Government understands from the United States Marshals Service (\"USMS\") that the USMS is acting expeditiously to transport the defendant into this District. In particular, the Government understands that the USMS expects that the defendant will arrive in this District early this week, well within the ten days contemplated by the Speedy Trial Act for transfer of a defendant from another district. See 18 U.S.C. § 3161(h)(1)(F).\n\nThe Government has consulted with defense counsel, Christian Everdell, Esq., who has requested that the arraignment, initial appearance, and bail hearing in this matter take place on July 10, 2020. In advance of that proceeding, the parties jointly request that the defense be permitted to file a written bail application to the Court by 3:00 p.m. on July 9, 2020, and that the Government be permitted to file a written reply by 12:00 p.m. on July 10, 2020. If that schedule is acceptable to the Court, the parties respectfully request that the Court schedule an arraignment, initial appearance, and bail hearing in this matter for the afternoon of July 10, 2020.\n\nAdditionally, the Government respectfully requests that the Court exclude time under the Speedy Trial Act between the defendant's arrest on July 2, 2020 and the date of the arraignment, initial appearance, and bail hearing before Your Honor. In addition to part of this time being necessary to transport the defendant to this District, and thus subject to an automatic exclusion of up to ten days from Speedy Trial Act calculation, see 18 U.S.C. § 3161(h)(1)(F), the Government\n\nDOJ-OGR-00001497",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 5 Filed 07/05/20 Page 1 of 2",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "U.S. Department of Justice\nUnited States Attorney\nSouthern District of New York\nThe Silvio J. Mollo Building\nOne Saint Andrew's Plaza\nNew York, New York 10007",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "July 5, 2020",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "VIA ECF\nThe Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\nUnited States Courthouse\n40 Foley Square\nNew 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:",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The Government respectfully submits this letter to request that the Court schedule an arraignment, initial appearance, and bail hearing in the above referenced case. On July 2, 2020, the defendant was arrested in Bradford, New Hampshire on the charges contained in the above-captioned Indictment and presented before a United States Magistrate Judge in the District of New Hampshire. At that appearance, the defendant waived her right to an identity hearing, consented to detention without prejudice to making a later application for bail, and consented to her transfer to the Southern District of New York.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "While the Government has no control over the timing of the defendant's transport, the Government understands from the United States Marshals Service (\"USMS\") that the USMS is acting expeditiously to transport the defendant into this District. In particular, the Government understands that the USMS expects that the defendant will arrive in this District early this week, well within the ten days contemplated by the Speedy Trial Act for transfer of a defendant from another district. See 18 U.S.C. § 3161(h)(1)(F).",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The Government has consulted with defense counsel, Christian Everdell, Esq., who has requested that the arraignment, initial appearance, and bail hearing in this matter take place on July 10, 2020. In advance of that proceeding, the parties jointly request that the defense be permitted to file a written bail application to the Court by 3:00 p.m. on July 9, 2020, and that the Government be permitted to file a written reply by 12:00 p.m. on July 10, 2020. If that schedule is acceptable to the Court, the parties respectfully request that the Court schedule an arraignment, initial appearance, and bail hearing in this matter for the afternoon of July 10, 2020.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Additionally, the Government respectfully requests that the Court exclude time under the Speedy Trial Act between the defendant's arrest on July 2, 2020 and the date of the arraignment, initial appearance, and bail hearing before Your Honor. In addition to part of this time being necessary to transport the defendant to this District, and thus subject to an automatic exclusion of up to ten days from Speedy Trial Act calculation, see 18 U.S.C. § 3161(h)(1)(F), the Government",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00001497",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ghislaine Maxwell",
      "Christian Everdell"
    ],
    "organizations": [
      "U.S. Department of Justice",
      "United States Attorney",
      "United States Marshals Service",
      "United States District Court"
    ],
    "locations": [
      "New York",
      "New Hampshire",
      "Bradford",
      "Southern District of New York"
    ],
    "dates": [
      "July 5, 2020",
      "July 2, 2020",
      "July 10, 2020",
      "July 9, 2020"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "20 Cr. 330 (AJN)",
      "DOJ-OGR-00001497"
    ]
  },
  "additional_notes": "The document appears to be a formal letter from the U.S. Department of Justice to the Honorable Alison J. Nathan, regarding the case United States v. Ghislaine Maxwell. The document is typed and contains no handwritten text or stamps."
}