mirror-epstein-docs/results/IMAGES008/DOJ-OGR-00020604.json

{
  "document_metadata": {
    "page_number": "3",
    "document_number": "40",
    "date": "01/12/2023",
    "document_type": "Court Document",
    "has_handwriting": true,
    "has_stamps": false
  },
  "full_text": "Case 22-1426, Document 40, 01/12/2023, 3451920, Page3 of 4\n\ndeadline of January 30, 2023, is the difficulty we have had communicating with our client who\nis incarcerated in Tallahassee, Florida, with limited phone access.\n\n8. We have been working diligently on this case and have identified several issues\nthat we believe merit appellate review. However, there is still considerable work to be done. We\nfind that we need an additional month beyond the current deadline to complete this important\nwork responsibly.\n\n9. We believe that the above represents extraordinary circumstances that justify the\nrelief sought. Denial of this application would cause irreparable harm to our client.\n\n10. Assistant United States Attorney Andrew Rohrbach informed me today that\nRespondent United States Attorney's Office of the Southern District of New York does not\nobject to the Court granting our motion for an additional one-month extension of time to file\nAppellant's brief.\n\n11. We respectfully request that the Court extend our time to file our brief to February\n28, 2023. We are cognizant that the Court warned that \"[f]urther extensions of time will be\ndisfavored.\" For this reason, we request only the additional time that we believe is absolutely\nnecessary in order to effectively represent our client.\n\nWHEREFORE, it is respectfully requested that this Court issue an Order granting\nAppellant's motion in its entirety, and for such other and further relief as this Court deems just\nand proper.\n\nDated: January 12, 2023\nNew York, New York\n\nRespectfully Submitted,\n\nAIDALA, BERTUNA & KAMINS, PC\nBy:\nJOHN M. LEVENTHAL, ESQ. (Ret.)\nAttorney for Defendant-Appellant\n\n2\nDOJ-OGR-00020604",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 22-1426, Document 40, 01/12/2023, 3451920, Page3 of 4",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "deadline of January 30, 2023, is the difficulty we have had communicating with our client who\nis incarcerated in Tallahassee, Florida, with limited phone access.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "8. We have been working diligently on this case and have identified several issues\nthat we believe merit appellate review. However, there is still considerable work to be done. We\nfind that we need an additional month beyond the current deadline to complete this important\nwork responsibly.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "9. We believe that the above represents extraordinary circumstances that justify the\nrelief sought. Denial of this application would cause irreparable harm to our client.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "10. Assistant United States Attorney Andrew Rohrbach informed me today that\nRespondent United States Attorney's Office of the Southern District of New York does not\nobject to the Court granting our motion for an additional one-month extension of time to file\nAppellant's brief.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "11. We respectfully request that the Court extend our time to file our brief to February\n28, 2023. We are cognizant that the Court warned that \"[f]urther extensions of time will be\ndisfavored.\" For this reason, we request only the additional time that we believe is absolutely\nnecessary in order to effectively represent our client.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "WHEREFORE, it is respectfully requested that this Court issue an Order granting\nAppellant's motion in its entirety, and for such other and further relief as this Court deems just\nand proper.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Dated: January 12, 2023\nNew York, New York",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "Respectfully Submitted,",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "AIDALA, BERTUNA & KAMINS, PC",
      "position": "bottom"
    },
    {
      "type": "handwritten",
      "content": "JOHN M. LEVENTHAL",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "By:\nJOHN M. LEVENTHAL, ESQ. (Ret.)\nAttorney for Defendant-Appellant",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "2",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00020604",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Andrew Rohrbach",
      "John M. Leventhal"
    ],
    "organizations": [
      "United States Attorney's Office",
      "Southern District of New York",
      "Aidala, Bertuna & Kamins, PC"
    ],
    "locations": [
      "Tallahassee",
      "Florida",
      "New York"
    ],
    "dates": [
      "January 30, 2023",
      "January 12, 2023",
      "February 28, 2023"
    ],
    "reference_numbers": [
      "Case 22-1426",
      "Document 40",
      "3451920",
      "DOJ-OGR-00020604"
    ]
  },
  "additional_notes": "The document appears to be a court filing with a signature from John M. Leventhal. The text is mostly printed, with a handwritten signature. There are no visible stamps or redactions."
}