mirror-epstein-docs/results/IMAGES001/DOJ-OGR-00002261.json

{
  "document_metadata": {
    "page_number": "1 of 2",
    "document_number": "102",
    "date": "01/08/21",
    "document_type": "letter",
    "has_handwriting": false,
    "has_stamps": true
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 102 Filed 01/08/21 Page 1 of 2\nCOHEN & GRESSER LLP\nChristian R. Everdell\n+1 (212) 957-7600\nceverdell@cohengresser.com\n800 Third Avenue\nNew York, NY 10022\nUSDC SDNY\nDOCUMENT\nELECTRONICALLY FILED\nDOC #: \nDATE FILED: 1/11/21\nJanuary 8, 2021\nBY ECF\nThe Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\nUnited States Courthouse\n40 Foley Square\nNew York, NY 10007\nRe: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)\nDear Judge Nathan:\nWe write on behalf of our client, Ghislaine Maxwell, to respectfully request a 30-day extension of time under Rule 4(b)(4) of the Federal Rules of Appellate Procedure to file our notice of appeal of the Court's order denying Ms. Maxwell's renewed motion for bail. (Dkt. 104, 106).\nRule 4(b)(4) provides that a district court may, upon a finding of \"good cause,\" extend the time to file a notice of appeal \"for a period not to exceed 30 days.\" Fed. R. App. P. 4(b)(4). In criminal cases, a defendant's notice of appeal must be filed \"within 14 days after ... the entry of either the judgment or the order being appealed.\" Fed. R. App. P. 4(b)(1)(A)(i). The Court's order denying Ms. Maxwell's renewed motion for bail was entered on December 28, 2020. (Dkt. 104, 106). Accordingly, Ms. Maxwell's notice of appeal of that order must be filed on or before Monday, January 11, 2021.\nThere is good cause for an extension here. Ms. Maxwell is considering whether to submit a third bail application to the Court, which would propose even more stringent and restrictive bail conditions than those proposed in the renewed bail application. The requested extension will give Ms. Maxwell the opportunity to research whether and to what extent these additional conditions are legally and practicably available, without forfeiting as untimely a possible appeal from the Court's December 28 Order denying the renewed bail application. The additional time is also warranted because it will enable the defense to continue its review of recently produced documents and to file our pretrial motions (each of which may bear on the merits of a possible third bail application); to research whether an appeal of the December 28 Order might deprive this Court of jurisdiction to address a third bail application; and because of logistical challenges posed by the continued effects of the pandemic.\nDOJ-OGR-00002261",
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      "content": "Case 1:20-cr-00330-AJN Document 102 Filed 01/08/21 Page 1 of 2",
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    {
      "type": "printed",
      "content": "COHEN & GRESSER LLP\nChristian R. Everdell\n+1 (212) 957-7600\nceverdell@cohengresser.com",
      "position": "header"
    },
    {
      "type": "stamp",
      "content": "USDC SDNY\nDOCUMENT\nELECTRONICALLY FILED\nDOC #: \nDATE FILED: 1/11/21",
      "position": "margin"
    },
    {
      "type": "printed",
      "content": "January 8, 2021\nBY ECF\nThe Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\nUnited States Courthouse\n40 Foley Square\nNew York, NY 10007",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)\nDear Judge Nathan:",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "We write on behalf of our client, Ghislaine Maxwell, to respectfully request a 30-day extension of time under Rule 4(b)(4) of the Federal Rules of Appellate Procedure to file our notice of appeal of the Court's order denying Ms. Maxwell's renewed motion for bail. (Dkt. 104, 106).",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Rule 4(b)(4) provides that a district court may, upon a finding of \"good cause,\" extend the time to file a notice of appeal \"for a period not to exceed 30 days.\" Fed. R. App. P. 4(b)(4). In criminal cases, a defendant's notice of appeal must be filed \"within 14 days after ... the entry of either the judgment or the order being appealed.\" Fed. R. App. P. 4(b)(1)(A)(i). The Court's order denying Ms. Maxwell's renewed motion for bail was entered on December 28, 2020. (Dkt. 104, 106). Accordingly, Ms. Maxwell's notice of appeal of that order must be filed on or before Monday, January 11, 2021.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "There is good cause for an extension here. Ms. Maxwell is considering whether to submit a third bail application to the Court, which would propose even more stringent and restrictive bail conditions than those proposed in the renewed bail application. The requested extension will give Ms. Maxwell the opportunity to research whether and to what extent these additional conditions are legally and practicably available, without forfeiting as untimely a possible appeal from the Court's December 28 Order denying the renewed bail application. The additional time is also warranted because it will enable the defense to continue its review of recently produced documents and to file our pretrial motions (each of which may bear on the merits of a possible third bail application); to research whether an appeal of the December 28 Order might deprive this Court of jurisdiction to address a third bail application; and because of logistical challenges posed by the continued effects of the pandemic.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00002261",
      "position": "footer"
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  ],
  "entities": {
    "people": [
      "Christian R. Everdell",
      "Alison J. Nathan",
      "Ghislaine Maxwell"
    ],
    "organizations": [
      "COHEN & GRESSER LLP",
      "United States District Court",
      "Southern District of New York"
    ],
    "locations": [
      "New York",
      "NY",
      "United States"
    ],
    "dates": [
      "January 8, 2021",
      "December 28, 2020",
      "January 11, 2021"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "Document 102",
      "20 Cr. 330 (AJN)",
      "Dkt. 104",
      "Dkt. 106",
      "DOJ-OGR-00002261"
    ]
  },
  "additional_notes": "The document appears to be a formal letter from a law firm to a judge, discussing a request for an extension of time to file a notice of appeal. The document is well-formatted and legible, with no visible redactions or damage."
}