mirror-epstein-docs/results/IMAGES002/DOJ-OGR-00005228.json

{
  "document_metadata": {
    "page_number": "3",
    "document_number": "345",
    "date": "October 14, 2021",
    "document_type": "Court Document",
    "has_handwriting": true,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 345 Filed 10/14/21 Page 3 of 3\nThe Honorable Alison J. Nathan\nOctober 14, 2021\nPage 3\nher counsel cannot adequately consult with her about the defense. Allowing Ms. Maxwell to file\nher Rule 412 motion 14 days before trial, as the Rule itself provides, is essential for counsel to\neffectively consult with Ms. Maxwell, to investigate and research what evidence they will seek to\nadmit under Rule 412, as well as to comply with the several procedural steps required by the\nRule.\nAccordingly, unless this Court orders otherwise, Ms. Maxwell will file her Rule 412\nmotion on or before November 15, 2021, as provided in Rule 412(c)(1)(B).\nRespectfully Submitted,\nJeffrey S. Pagliuca\nCC: Counsel of Record (via ECF)",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 345 Filed 10/14/21 Page 3 of 3",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "The Honorable Alison J. Nathan\nOctober 14, 2021\nPage 3",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "her counsel cannot adequately consult with her about the defense. Allowing Ms. Maxwell to file\nher Rule 412 motion 14 days before trial, as the Rule itself provides, is essential for counsel to\neffectively consult with Ms. Maxwell, to investigate and research what evidence they will seek to\nadmit under Rule 412, as well as to comply with the several procedural steps required by the\nRule.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Accordingly, unless this Court orders otherwise, Ms. Maxwell will file her Rule 412\nmotion on or before November 15, 2021, as provided in Rule 412(c)(1)(B).",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Respectfully Submitted,",
      "position": "body"
    },
    {
      "type": "handwritten",
      "content": "/s/",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Jeffrey S. Pagliuca",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "CC: Counsel of Record (via ECF)",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ms. Maxwell",
      "Jeffrey S. Pagliuca"
    ],
    "organizations": [],
    "locations": [],
    "dates": [
      "October 14, 2021",
      "November 15, 2021"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 345",
      "Rule 412",
      "Rule 412(c)(1)(B)"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is mostly printed, with a single handwritten signature. There are no visible stamps or redactions."
}