mirror-epstein-docs/results/IMAGES002/DOJ-OGR-00005020.json

{
  "document_metadata": {
    "page_number": "2",
    "document_number": "331",
    "date": "August 30, 2021",
    "document_type": "Court Document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 331 Filed 08/30/21 Page 2 of 5\nThe Honorable Alison J. Nathan\nAugust 30, 2021\nPage 2\nThe government's objection is, in substance, a motion to reconsider. \"There is 'no specific rule, either in the Federal Rules of Criminal Procedure or in this district's local criminal rules that provide for reconsideration of a ruling in a criminal matter.'\" United States v. Okparaeke, No. 17-CR-225 (NSR), 2019 WL 4233427, at *2 (S.D.N.Y. Sept. 6, 2019) (quoting United States v. Cartagena, No. 10 Cr. 222-2, 2012 WL 2958175, at *1 (S.D.N.Y. July 20, 2012)). Even so, courts have discretion to reconsider prior rulings in criminal cases when the moving party can point to \"controlling law or factual matters which it believes the court overlooked and that might reasonably be expected to alter the court's decision.\" United States v. Berger, 188 F. Supp. 2d 307, 328-39 (S.D.N.Y. 2002).\nBut \"[t]he standard for granting a motion for reconsideration 'is strict.'\" Farmer v. United States, No. 12-CR-758/15-cv-6287 (AJN), 2017 WL 3448014, at *2 (S.D.N.Y. Aug. 10, 2017) (quoting Analytical Surveys, Inc. v. Tonga Partners, L.P., 684 F.3d 36, 52 (2d.Cir. 2012)). That's because \"[r]econsideration of a court's previous order is an 'extraordinary remedy to be employed in the interests of finality and conservation of scarce judicial resources.'\" Montanile v. Nat'l Broad. Co., 216 F. Supp. 2d 341, 342 (S.D.N.Y. 2002).\nThe government cannot show extraordinary circumstances here. The government twice had notice of Ms. Maxwell's request for disclosure, and the government twice chose not to object. The government cannot use a motion to reconsider to save itself from the consequences of its deliberate decisions. \"[A] losing party\" is not permitted to \"examin[e] a decision and then plug[] in the gaps of a lost motion with additional matters.\" Berger, 188 F. Supp. 2d at 339.\nBecause that is exactly what the government is attempting to do, this Court should deny the government's request. Ms. Maxwell is entitled to the disclosure this Court ordered.\nDOJ-OGR-00005020",
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      "content": "Case 1:20-cr-00330-PAE Document 331 Filed 08/30/21 Page 2 of 5",
      "position": "header"
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    {
      "type": "printed",
      "content": "The Honorable Alison J. Nathan\nAugust 30, 2021\nPage 2",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "The government's objection is, in substance, a motion to reconsider. \"There is 'no specific rule, either in the Federal Rules of Criminal Procedure or in this district's local criminal rules that provide for reconsideration of a ruling in a criminal matter.'\" United States v. Okparaeke, No. 17-CR-225 (NSR), 2019 WL 4233427, at *2 (S.D.N.Y. Sept. 6, 2019) (quoting United States v. Cartagena, No. 10 Cr. 222-2, 2012 WL 2958175, at *1 (S.D.N.Y. July 20, 2012)). Even so, courts have discretion to reconsider prior rulings in criminal cases when the moving party can point to \"controlling law or factual matters which it believes the court overlooked and that might reasonably be expected to alter the court's decision.\" United States v. Berger, 188 F. Supp. 2d 307, 328-39 (S.D.N.Y. 2002).\nBut \"[t]he standard for granting a motion for reconsideration 'is strict.'\" Farmer v. United States, No. 12-CR-758/15-cv-6287 (AJN), 2017 WL 3448014, at *2 (S.D.N.Y. Aug. 10, 2017) (quoting Analytical Surveys, Inc. v. Tonga Partners, L.P., 684 F.3d 36, 52 (2d.Cir. 2012)). That's because \"[r]econsideration of a court's previous order is an 'extraordinary remedy to be employed in the interests of finality and conservation of scarce judicial resources.'\" Montanile v. Nat'l Broad. Co., 216 F. Supp. 2d 341, 342 (S.D.N.Y. 2002).\nThe government cannot show extraordinary circumstances here. The government twice had notice of Ms. Maxwell's request for disclosure, and the government twice chose not to object. The government cannot use a motion to reconsider to save itself from the consequences of its deliberate decisions. \"[A] losing party\" is not permitted to \"examin[e] a decision and then plug[] in the gaps of a lost motion with additional matters.\" Berger, 188 F. Supp. 2d at 339.\nBecause that is exactly what the government is attempting to do, this Court should deny the government's request. Ms. Maxwell is entitled to the disclosure this Court ordered.",
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      "content": "DOJ-OGR-00005020",
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  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ms. Maxwell"
    ],
    "organizations": [
      "United States",
      "Department of Justice"
    ],
    "locations": [
      "S.D.N.Y.",
      "New York"
    ],
    "dates": [
      "August 30, 2021",
      "September 6, 2019",
      "July 20, 2012",
      "August 10, 2017",
      "2002"
    ],
    "reference_numbers": [
      "Case 1:20-cr-00330-PAE",
      "Document 331",
      "No. 17-CR-225 (NSR)",
      "No. 10 Cr. 222-2",
      "No. 12-CR-758/15-cv-6287 (AJN)",
      "DOJ-OGR-00005020"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is well-formatted and legible. There are no visible redactions or damages."
}