mirror-epstein-docs/results/IMAGES002/DOJ-OGR-00004952.json

{
  "document_metadata": {
    "page_number": "1",
    "document_number": "313",
    "date": "07/09/21",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 313 Filed 07/09/21 Page 1 of 3\nLAW OFFICES OF BOBBI C. STERNHEIM\n212-243-1100 · Main 917-306-6666 · Cell 888-587-4737 · Fax 33 West 19th Street - 4th Floor New York, New York 10011 bc@sternheimlaw.com\nJuly 9, 2021\nHonorable Alison J. Nathan United States District Judge United States Courthouse 40 Foley Square New York, NY 10007\nRe: United States v. Ghislaine Maxwell S2 20 Cr. 330 (AJN)\nDear Judge Nathan:\nThe below-signed counsel of record for Ghislaine Maxwell submit this letter in response to the Court's order of July 2, 2021. (Dkt. 312).\nMs. Maxwell's counsel of record have scrupulously complied with Local Criminal Rule 23.1 and assiduously refrained from any involvement with the media, despite repeated, persistent and borderline-harassing requests for comment. The statements in the New York Daily News Op-Ed piece were from Mr. Markus, who is not counsel of record in this case. These statements did not violate Rule 23.1. Nevertheless, it is appropriate that Mr. Markus, not Ms. Maxwell's counsel of record, be afforded the opportunity to address the government's unfounded complaints by separate letter response.1\nWe feel compelled to point out, however, that the government's position betrays a double standard that exists for public statements made by the government, its agents, and the alleged accusers and their counsel.\nAfter Ms. Maxwell was arrested just over a year ago, Acting U.S. Attorney Audrey Strauss gave a deliberate press conference in blatant violation of Rule 23.1 espousing comment and opinion beyond the facts and circumstances of the arrest. The government filed a \"speaking record.\n1 Indeed, the government's letter to the Court raising this issue was directed to Mr. Markus, not counsel of record.\nDOJ-OGR-00004952",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 313 Filed 07/09/21 Page 1 of 3",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "LAW OFFICES OF BOBBI C. STERNHEIM",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "212-243-1100 · Main 917-306-6666 · Cell 888-587-4737 · Fax 33 West 19th Street - 4th Floor New York, New York 10011 bc@sternheimlaw.com",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "July 9, 2021",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Honorable Alison J. Nathan United States District Judge United States Courthouse 40 Foley Square New York, NY 10007",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Re: United States v. Ghislaine Maxwell S2 20 Cr. 330 (AJN)",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Dear Judge Nathan:",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The below-signed counsel of record for Ghislaine Maxwell submit this letter in response to the Court's order of July 2, 2021. (Dkt. 312).",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Ms. Maxwell's counsel of record have scrupulously complied with Local Criminal Rule 23.1 and assiduously refrained from any involvement with the media, despite repeated, persistent and borderline-harassing requests for comment. The statements in the New York Daily News Op-Ed piece were from Mr. Markus, who is not counsel of record in this case. These statements did not violate Rule 23.1. Nevertheless, it is appropriate that Mr. Markus, not Ms. Maxwell's counsel of record, be afforded the opportunity to address the government's unfounded complaints by separate letter response.1",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "We feel compelled to point out, however, that the government's position betrays a double standard that exists for public statements made by the government, its agents, and the alleged accusers and their counsel.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "After Ms. Maxwell was arrested just over a year ago, Acting U.S. Attorney Audrey Strauss gave a deliberate press conference in blatant violation of Rule 23.1 espousing comment and opinion beyond the facts and circumstances of the arrest. The government filed a \"speaking record.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "1 Indeed, the government's letter to the Court raising this issue was directed to Mr. Markus, not counsel of record.",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00004952",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ghislaine Maxwell",
      "Mr. Markus",
      "Audrey Strauss"
    ],
    "organizations": [
      "Law Offices of Bobbi C. Sternheim",
      "United States District Judge",
      "United States Courthouse",
      "New York Daily News"
    ],
    "locations": [
      "New York",
      "Foley Square"
    ],
    "dates": [
      "July 9, 2021",
      "July 2, 2021"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "Document 313",
      "S2 20 Cr. 330 (AJN)",
      "Dkt. 312",
      "DOJ-OGR-00004952"
    ]
  },
  "additional_notes": "The document appears to be a formal letter from the Law Offices of Bobbi C. Sternheim to Judge Alison J. Nathan regarding the case United States v. Ghislaine Maxwell. The letter is typed and contains no handwritten text or stamps. The document is in good condition with no visible damage or redactions."
}