mirror-epstein-docs/results/IMAGES002/DOJ-OGR-00004955.json

{
  "document_metadata": {
    "page_number": "1",
    "document_number": "314",
    "date": "07/12/21",
    "document_type": "Letter to Chambers",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 314 Filed 07/12/21 Page 1 of 7\nMARKUS / MOSS\nJuly 9, 2021\nVIA EMAIL TO CHAMBERS\nThe Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\n40 Foley Square\nNew York, New York 10007\nRe: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)\nDear Judge Nathan:\nEven though I do not currently represent Ms. Maxwell in any proceedings and have never entered an appearance in connection with her trial before Your Honor, the Government submitted a letter \"to bring to the Court's attention\" an article that I wrote on June 30, 2021, and asked that the Court \"issue an order pursuant to Local Rule 23.1(h)\" directed at me. (Dkt. No. 309). This Court ordered that I respond (Dkt. No. 312), and I do so here. I respectfully request that the Court deny the Government's request for the following reasons:\nI. The local rules do not apply as I do not currently represent Ghislaine Maxwell in any proceeding and have not entered an appearance in this Court.\nBecause undersigned counsel does not currently represent Ms. Maxwell in any court and has never entered an appearance as her lawyer in this Court, the local rules do not apply. See, e.g., Local Rule 23.1(h) (explaining that the Court \"may issue a special order governing such matters as extrajudicial statements by parties and witnesses likely to interfere with the rights of the accused to a fair trial by an impartial jury\") (emphasis added). Because undersigned counsel does not represent a party or a witness, the Government's request should be denied.\nUndersigned counsel was previously retained to represent Ms. Maxwell's family. Then, when this Court denied her third bail application, undersigned counsel was retained to represent Ms. Maxwell in the Second Circuit on her bail appeal (and not regarding the merits of the case). That proceeding is concluded, and undersigned counsel no longer represents Ms. Maxwell in any capacity.\nMARKUS/MOSS PLLC\n40 NW 3rd Street, PH 1\nMiami, FL 33128\nT 305 379-6667\nF 305 379-6668\nmarkuslaw.com\nDOJ-OGR-00004955",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 314 Filed 07/12/21 Page 1 of 7",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "MARKUS / MOSS",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "July 9, 2021",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "VIA EMAIL TO CHAMBERS\nThe Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\n40 Foley Square\nNew York, New York 10007\nRe: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)\nDear Judge Nathan:",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Even though I do not currently represent Ms. Maxwell in any proceedings and have never entered an appearance in connection with her trial before Your Honor, the Government submitted a letter \"to bring to the Court's attention\" an article that I wrote on June 30, 2021, and asked that the Court \"issue an order pursuant to Local Rule 23.1(h)\" directed at me. (Dkt. No. 309). This Court ordered that I respond (Dkt. No. 312), and I do so here. I respectfully request that the Court deny the Government's request for the following reasons:",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "I. The local rules do not apply as I do not currently represent Ghislaine Maxwell in any proceeding and have not entered an appearance in this Court.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Because undersigned counsel does not currently represent Ms. Maxwell in any court and has never entered an appearance as her lawyer in this Court, the local rules do not apply. See, e.g., Local Rule 23.1(h) (explaining that the Court \"may issue a special order governing such matters as extrajudicial statements by parties and witnesses likely to interfere with the rights of the accused to a fair trial by an impartial jury\") (emphasis added). Because undersigned counsel does not represent a party or a witness, the Government's request should be denied.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Undersigned counsel was previously retained to represent Ms. Maxwell's family. Then, when this Court denied her third bail application, undersigned counsel was retained to represent Ms. Maxwell in the Second Circuit on her bail appeal (and not regarding the merits of the case). That proceeding is concluded, and undersigned counsel no longer represents Ms. Maxwell in any capacity.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "MARKUS/MOSS PLLC\n40 NW 3rd Street, PH 1\nMiami, FL 33128\nT 305 379-6667\nF 305 379-6668\nmarkuslaw.com",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00004955",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ghislaine Maxwell"
    ],
    "organizations": [
      "United States District Court",
      "Southern District of New York",
      "MARKUS/MOSS PLLC"
    ],
    "locations": [
      "New York",
      "Miami",
      "FL"
    ],
    "dates": [
      "July 9, 2021",
      "June 30, 2021",
      "07/12/21"
    ],
    "reference_numbers": [
      "20 Cr. 330 (AJN)",
      "Dkt. No. 309",
      "Dkt. No. 312",
      "DOJ-OGR-00004955"
    ]
  },
  "additional_notes": "The document appears to be a formal letter to a judge regarding a court case. The text is clear and legible, with no visible redactions or damage."
}