mirror-epstein-docs/results/IMAGES001/DOJ-OGR-00002885.json

{
  "document_metadata": {
    "page_number": "2",
    "document_number": "192",
    "date": "03/31/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-000330-AJN Document 192 Filed 03/31/21 Page 2 of 3\nLAW OFFICES OF BOBBI C. STERNHEIM\nTo be clear, any such request will not be made from any desire of Ms. Maxwell to delay her trial but rests squarely on the government's late, tactical, expansion of this prosecution.\nAt the initial appearance on July 14, 2020, the defense agreed to the July 12th trial date based on the government's representation that is would not file a superseding indictment:\nThe trial schedule that we are agreeing to, of course subject to the court's approval, assumes there will be no substantive superseding indictment. If there is one, which the government has advised us they don't believe is imminent or I assume not at all, we might have to come back to the court to address not just trial schedule but other schedule as well.\nJuly 14, 2020 Transcript at 16 -17 (emphasis added).\nIn response, the Court made the following inquiry:\nLet me go ahead and ask, Ms. Moe, Mr. Cohen has made a representation but I will ask if you do anticipate at this time filing any further superseding indictments adding either defendants or additional charges?\nId. at 17.\nThe government confirmed:\nMS. MOE: Your Honor, our investigation remains ongoing, but at this point we do not currently anticipate seeking a superseding indictment.\nId.\nBased on that representation, Ms. Maxwell accepted a July 12, 2021 trial date and her lawyers planned accordingly, postponing trials in other cases to preserve this high-priority date. It was only after considerable judicial and defense resources were expended that the government belatedly superseded, again, with no justifiable reason given the age of these allegations. The timing suggests that the decision to supersede was prompted by the filing of defense pretrial motions and government concern about the now-apparent weakness of its case. The government may be entitled to supersede but not when its decision disrupts the schedule set by the Court and relied on by Ms. Maxwell. This delay has a prejudicial effect on counsel's readiness for trial and Ms. Maxwell's prolonged detention.\nThis is no longer the \"two-week\" trial as represented by the government. By adding charges that encompass dozens of additional witnesses, the government has unilaterally destroyed the possibility that this case can be completed in the time allotted. The continual media attention this case garners, in addition to podcasts, documentaries, books and the like, will likely require the bulk of that time to seat a fair and impartial jury, provided that constitutional right can be guaranteed.\n2\nDOJ-OGR-00002885",
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      "content": "Case 1:20-cr-000330-AJN Document 192 Filed 03/31/21 Page 2 of 3",
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    {
      "type": "printed",
      "content": "LAW OFFICES OF BOBBI C. STERNHEIM",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "To be clear, any such request will not be made from any desire of Ms. Maxwell to delay her trial but rests squarely on the government's late, tactical, expansion of this prosecution.",
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    },
    {
      "type": "printed",
      "content": "At the initial appearance on July 14, 2020, the defense agreed to the July 12th trial date based on the government's representation that is would not file a superseding indictment:",
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    },
    {
      "type": "printed",
      "content": "The trial schedule that we are agreeing to, of course subject to the court's approval, assumes there will be no substantive superseding indictment. If there is one, which the government has advised us they don't believe is imminent or I assume not at all, we might have to come back to the court to address not just trial schedule but other schedule as well.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "July 14, 2020 Transcript at 16 -17 (emphasis added).",
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    {
      "type": "printed",
      "content": "In response, the Court made the following inquiry:",
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    },
    {
      "type": "printed",
      "content": "Let me go ahead and ask, Ms. Moe, Mr. Cohen has made a representation but I will ask if you do anticipate at this time filing any further superseding indictments adding either defendants or additional charges?",
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    {
      "type": "printed",
      "content": "Id. at 17.",
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    {
      "type": "printed",
      "content": "The government confirmed:",
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    {
      "type": "printed",
      "content": "MS. MOE: Your Honor, our investigation remains ongoing, but at this point we do not currently anticipate seeking a superseding indictment.",
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    },
    {
      "type": "printed",
      "content": "Id.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Based on that representation, Ms. Maxwell accepted a July 12, 2021 trial date and her lawyers planned accordingly, postponing trials in other cases to preserve this high-priority date. It was only after considerable judicial and defense resources were expended that the government belatedly superseded, again, with no justifiable reason given the age of these allegations. The timing suggests that the decision to supersede was prompted by the filing of defense pretrial motions and government concern about the now-apparent weakness of its case. The government may be entitled to supersede but not when its decision disrupts the schedule set by the Court and relied on by Ms. Maxwell. This delay has a prejudicial effect on counsel's readiness for trial and Ms. Maxwell's prolonged detention.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "This is no longer the \"two-week\" trial as represented by the government. By adding charges that encompass dozens of additional witnesses, the government has unilaterally destroyed the possibility that this case can be completed in the time allotted. The continual media attention this case garners, in addition to podcasts, documentaries, books and the like, will likely require the bulk of that time to seat a fair and impartial jury, provided that constitutional right can be guaranteed.",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "2",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00002885",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Ms. Maxwell",
      "Ms. Moe",
      "Mr. Cohen"
    ],
    "organizations": [
      "LAW OFFICES OF BOBBI C. STERNHEIM"
    ],
    "locations": [],
    "dates": [
      "July 14, 2020",
      "July 12, 2021",
      "03/31/21"
    ],
    "reference_numbers": [
      "Case 1:20-cr-000330-AJN",
      "Document 192",
      "DOJ-OGR-00002885"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Ms. Maxwell. The text is printed and there are no visible stamps or handwritten notes. The document is page 2 of 3."
}