mirror-epstein-docs/results/IMAGES001/DOJ-OGR-00001536.json

{
  "document_metadata": {
    "page_number": "1 of 2",
    "document_number": "8",
    "date": "07/06/20",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 8 Filed 07/06/20 Page 1 of 2 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 July 6, 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 in response to the Court's order from earlier today regarding the scheduling of the arraignment, initial appearance, and bail hearing in this matter. We have been attempting to contact our client at the Metropolitan Detention Center; we were able to speak to her for the first time today just before 9:00pm this evening. She has agreed to waive her physical presence for these proceedings. As directed by the Court, we have met and conferred with the Government regarding scheduling. All parties will be able to proceed remotely on the morning of July 14, 2020. The defense will not be able to proceed on July 9, 2020. We will meet and confer further with the Government tomorrow regarding a proposed briefing schedule and anticipate providing a joint proposed briefing schedule for the Court's consideration by the end of the day. Respectfully submitted, /s/ Mark S. Cohen Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue, 21st Floor DOJ-OGR-00001536",
  "text_blocks": [
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      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 8 Filed 07/06/20 Page 1 of 2",
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    {
      "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",
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    },
    {
      "type": "printed",
      "content": "July 6, 2020",
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    {
      "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 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan:",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "On behalf of our client, Ghislaine Maxwell, we respectfully submit this letter in response to the Court's order from earlier today regarding the scheduling of the arraignment, initial appearance, and bail hearing in this matter. We have been attempting to contact our client at the Metropolitan Detention Center; we were able to speak to her for the first time today just before 9:00pm this evening. She has agreed to waive her physical presence for these proceedings. As directed by the Court, we have met and conferred with the Government regarding scheduling. All parties will be able to proceed remotely on the morning of July 14, 2020. The defense will not be able to proceed on July 9, 2020. We will meet and confer further with the Government tomorrow regarding a proposed briefing schedule and anticipate providing a joint proposed briefing schedule for the Court's consideration by the end of the day.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Respectfully submitted, /s/ Mark S. Cohen Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue, 21st Floor",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00001536",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Mark S. Cohen",
      "Christian R. Everdell",
      "Alison J. Nathan",
      "Ghislaine Maxwell"
    ],
    "organizations": [
      "COHEN & GRESSER LLP",
      "United States District Court",
      "Southern District of New York",
      "Metropolitan Detention Center",
      "Government"
    ],
    "locations": [
      "New York",
      "NY",
      "United States"
    ],
    "dates": [
      "July 6, 2020",
      "July 14, 2020",
      "July 9, 2020"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "20 Cr. 330 (AJN)",
      "DOJ-OGR-00001536"
    ]
  },
  "additional_notes": "The document is a letter from COHEN & GRESSER LLP to the Honorable Alison J. Nathan regarding the case United States v. Ghislaine Maxwell. The letter is dated July 6, 2020, and is filed as Document 8 in the case."
}