mirror-epstein-docs/results/IMAGES002/DOJ-OGR-00004994.json

{
  "document_metadata": {
    "page_number": "1",
    "document_number": "320",
    "date": "August 18, 2021",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": true
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 320 Filed 08/18/21 Page 1 of 4\nU.S. Department of Justice\nUnited States Attorney\nSouthern District of New York\nThe Silvio J. Mollo Building\nOne Saint Andrew's Plaza\nNew York, New York 10007\nAugust 18, 2021\nVIA ECF\nThe Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\nUnited States Courthouse\n40 Foley Square\nNew York, New York 10007\nRe: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)\nDear Judge Nathan:\nThe Government respectfully submits this letter in response to footnote 1 of the Court's Opinion and Order denying the defendant Ghislaine Maxwell's supplemental pretrial motions.\n(Dkt. No. 317). In that footnote, the Court noted that the defendant's motion for a bill of particulars included a request that the Government identify her unnamed co-conspirators, as did her position in the parties' joint letter regarding the disclosure schedule.\nThe Court wrote that, because the Government had not objected, it \"presumes the Government intends to disclose this information to Maxwell at the same time that . . . it discloses Jencks Act material.\" (Id. at 12 n.1).\nTo be clear, the Government objects to any requirement that it provide an exhaustive list of co-conspirators, whether in a bill of particulars or otherwise, and does not intend to do so absent further order of the Court.1\n1 The Government has opposed the defendant's requests for such a list as part of its opposition to the defense motions for a bill of particulars.\nIn the parties' joint letter regarding the disclosure schedule, the defendant sought early disclosure of both the identities of unindicted co-conspirators and their statements.\n(Dkt. No. 291 at 7-8, 10-13). The Government took the position that the defense could \"receive notice of any co-conspirator statements through Jencks Act materials and marked exhibits.\" (Id. at 5).\nThe Government also noted that \"[t]he cases cited by the defense all DOJ-OGR-00004994",
  "text_blocks": [
    {
      "type": "header",
      "content": "U.S. Department of Justice\nUnited States Attorney\nSouthern District of New York",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The Silvio J. Mollo Building\nOne Saint Andrew's Plaza\nNew York, New York 10007\nAugust 18, 2021",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "VIA ECF\nThe Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\nUnited States Courthouse\n40 Foley Square\nNew York, New York 10007",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)\nDear Judge Nathan:",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The Government respectfully submits this letter in response to footnote 1 of the Court's Opinion and Order denying the defendant Ghislaine Maxwell's supplemental pretrial motions.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "(Dkt. No. 317). In that footnote, the Court noted that the defendant's motion for a bill of particulars included a request that the Government identify her unnamed co-conspirators, as did her position in the parties' joint letter regarding the disclosure schedule.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The Court wrote that, because the Government had not objected, it \"presumes the Government intends to disclose this information to Maxwell at the same time that . . . it discloses Jencks Act material.\" (Id. at 12 n.1).",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "To be clear, the Government objects to any requirement that it provide an exhaustive list of co-conspirators, whether in a bill of particulars or otherwise, and does not intend to do so absent further order of the Court.1",
      "position": "middle"
    },
    {
      "type": "footnote",
      "content": "1 The Government has opposed the defendant's requests for such a list as part of its opposition to the defense motions for a bill of particulars.",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "In the parties' joint letter regarding the disclosure schedule, the defendant sought early disclosure of both the identities of unindicted co-conspirators and their statements.",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "(Dkt. No. 291 at 7-8, 10-13). The Government took the position that the defense could \"receive notice of any co-conspirator statements through Jencks Act materials and marked exhibits.\" (Id. at 5).",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "The Government also noted that \"[t]he cases cited by the defense all",
      "position": "bottom"
    },
    {
      "type": "stamp",
      "content": "DOJ-OGR-00004994",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Ghislaine Maxwell",
      "Alison J. Nathan"
    ],
    "organizations": [
      "U.S. Department of Justice",
      "United States Attorney",
      "United States District Court"
    ],
    "locations": [
      "New York",
      "Southern District of New York"
    ],
    "dates": [
      "August 18, 2021"
    ],
    "reference_numbers": [
      "20 Cr. 330 (AJN)",
      "Dkt. No. 317",
      "Dkt. No. 291",
      "DOJ-OGR-00004994"
    ]
  },
  "additional_notes": "The document appears to be a formal letter from the U.S. Department of Justice to the Honorable Alison J. Nathan, regarding the case United States v. Ghislaine Maxwell. The document is stamped with a DOJ reference number."
}