mirror-epstein-docs/results/IMAGES001/DOJ-OGR-00002269.json

{
  "document_metadata": {
    "page_number": "2",
    "document_number": "115",
    "date": "01/14/21",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 115 Filed 01/14/21 Page 2 of 2\n\nThe Honorable Alison J. Nathan\nJanuary 14, 2021\nPage 2\n\nwould not require any change in Ms. Maxwell's movements to give her the requested access. Furthermore, on at least three occasions since she was released from quarantine, Ms. Maxwell's security team gave her the laptop to review discovery on the weekend.\n\nThere is clearly no actual impediment preventing the MDC staff from providing Ms. Maxwell access to the laptop on weekends and holidays. Given the millions of documents that Ms. Maxwell must review before trial in order to prepare her defense, it is critical that she be given as much time as possible with the laptop to review the discovery. We therefore respectfully request that the Court order the BOP to give Ms. Maxwell access to the laptop on weekends and holidays during the hours that she is permitted to review discovery.\n\nSincerely,\n\n/s/ Christian Everdell\nChristian R. Everdell\nCOHEN & GRESSER LLP\n800 Third Avenue, 21st Floor\nNew York, New York 10022\n(212) 957-7600\n\ncc: All Counsel of Record (By ECF)\n\nDOJ-OGR-00002269",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 115 Filed 01/14/21 Page 2 of 2",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "The Honorable Alison J. Nathan\nJanuary 14, 2021\nPage 2",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "would not require any change in Ms. Maxwell's movements to give her the requested access. Furthermore, on at least three occasions since she was released from quarantine, Ms. Maxwell's security team gave her the laptop to review discovery on the weekend.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "There is clearly no actual impediment preventing the MDC staff from providing Ms. Maxwell access to the laptop on weekends and holidays. Given the millions of documents that Ms. Maxwell must review before trial in order to prepare her defense, it is critical that she be given as much time as possible with the laptop to review the discovery. We therefore respectfully request that the Court order the BOP to give Ms. Maxwell access to the laptop on weekends and holidays during the hours that she is permitted to review discovery.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Sincerely,",
      "position": "body"
    },
    {
      "type": "signature",
      "content": "/s/ Christian Everdell",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Christian R. Everdell\nCOHEN & GRESSER LLP\n800 Third Avenue, 21st Floor\nNew York, New York 10022\n(212) 957-7600",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "cc: All Counsel of Record (By ECF)",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00002269",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ms. Maxwell",
      "Christian Everdell",
      "Christian R. Everdell"
    ],
    "organizations": [
      "COHEN & GRESSER LLP",
      "MDC",
      "BOP"
    ],
    "locations": [
      "New York"
    ],
    "dates": [
      "January 14, 2021",
      "01/14/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "Document 115",
      "DOJ-OGR-00002269"
    ]
  },
  "additional_notes": "The document appears to be a formal letter from Christian R. Everdell to The Honorable Alison J. Nathan regarding a court case involving Ms. Maxwell. The letter is typed and signed electronically. There are no visible redactions or damage to the document."
}