mirror-epstein-docs/results/IMAGES002/DOJ-OGR-00005246.json

{
  "document_metadata": {
    "page_number": "1",
    "document_number": "3354",
    "date": "October 15, 2021",
    "document_type": "Letter",
    "has_handwriting": true,
    "has_stamps": false
  },
  "full_text": "Case#: 2020cr00338(PAE) Document#: 3354 Filed: 10/15/21 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\nOctober 15, 2021\nUSDC SDNY\nDOCUMENT\nELECTRONICALLY FILED\nDOC#:\nDATE FILED: 10/15/21\nBY 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 the Court's Order dated October 14, 2021 (Dkt. No. 347) ordering the Government to respond to the defendant's October 14, 2021 letter regarding the deadline for filing a motion under Federal Rule of Evidence 412 (Dkt. No. 345). In particular, the defendant wrote the Court to \"confirm that November 15, 2021 is the deadline for [her] to file a motion under Federal Rule of Evidence 412.\" (Dkt. No. 345).\nFederal Rule of Evidence 412(a)(1) provides that in a case involving allegations of sexual misconduct, \"evidence offered to prove that a victim engaged in other sexual behavior\" is inadmissible. The Rule \"aims to safeguard the alleged victim against the invasion of privacy, potential embarrassment and sexual stereotyping that is associated with public disclosure of intimate sexual details.\" United States v. Rivera, 799 F.3d 180, 184 (2d Cir. 2015) (quoting Fed. R. Evid. 412 advisory committee's note). \"The exclusion, however, is not absolute\" as Rule 412(b) provides certain exceptions to this general prohibition in criminal cases. Id. Rule 412 provides that \"[i]f a party intends to offer evidence under Rule 412(b),\" the party must file a motion specifically describing the evidence and the purpose of the evidence, Fed. R. Evid. 412(c)(1)(A),\nFor the reasons stated in this letter, the Court finds that there is good cause for any motion under Federal Rule of Evidence 412 to be filed no later than October 27, 2021. Any response will be due November 1, 2021. Any hearing will tentatively be scheduled for November 5, 2021. Additional details will be provided if and when any motions are filed. SO ORDERED.\nAlison J. Nathan 10/15/21\nDOJ-OGR-00005246",
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      "content": "Case#: 2020cr00338(PAE) Document#: 3354 Filed: 10/15/21 Page#: 1 of 4",
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    {
      "type": "printed",
      "content": "U.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",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "October 15, 2021",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "USDC SDNY\nDOCUMENT\nELECTRONICALLY FILED\nDOC#:\nDATE FILED: 10/15/21",
      "position": "left margin"
    },
    {
      "type": "printed",
      "content": "BY 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": "body"
    },
    {
      "type": "printed",
      "content": "Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Dear Judge Nathan:",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "The Government respectfully submits this letter in response to the Court's Order dated October 14, 2021 (Dkt. No. 347) ordering the Government to respond to the defendant's October 14, 2021 letter regarding the deadline for filing a motion under Federal Rule of Evidence 412 (Dkt. No. 345). In particular, the defendant wrote the Court to \"confirm that November 15, 2021 is the deadline for [her] to file a motion under Federal Rule of Evidence 412.\" (Dkt. No. 345).",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Federal Rule of Evidence 412(a)(1) provides that in a case involving allegations of sexual misconduct, \"evidence offered to prove that a victim engaged in other sexual behavior\" is inadmissible. The Rule \"aims to safeguard the alleged victim against the invasion of privacy, potential embarrassment and sexual stereotyping that is associated with public disclosure of intimate sexual details.\" United States v. Rivera, 799 F.3d 180, 184 (2d Cir. 2015) (quoting Fed. R. Evid. 412 advisory committee's note). \"The exclusion, however, is not absolute\" as Rule 412(b) provides certain exceptions to this general prohibition in criminal cases. Id. Rule 412 provides that \"[i]f a party intends to offer evidence under Rule 412(b),\" the party must file a motion specifically describing the evidence and the purpose of the evidence, Fed. R. Evid. 412(c)(1)(A),",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "For the reasons stated in this letter, the Court finds that there is good cause for any motion under Federal Rule of Evidence 412 to be filed no later than October 27, 2021. Any response will be due November 1, 2021. Any hearing will tentatively be scheduled for November 5, 2021. Additional details will be provided if and when any motions are filed. SO ORDERED.",
      "position": "body"
    },
    {
      "type": "handwritten",
      "content": "Alison J. Nathan 10/15/21",
      "position": "signature"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00005246",
      "position": "footer"
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  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ghislaine Maxwell"
    ],
    "organizations": [
      "U.S. Department of Justice",
      "United States District Court",
      "United States Courthouse"
    ],
    "locations": [
      "New York"
    ],
    "dates": [
      "October 15, 2021",
      "October 14, 2021",
      "October 27, 2021",
      "November 1, 2021",
      "November 5, 2021",
      "November 15, 2021"
    ],
    "reference_numbers": [
      "20 Cr. 330 (AJN)",
      "Dkt. No. 347",
      "Dkt. No. 345",
      "DOJ-OGR-00005246"
    ]
  },
  "additional_notes": "The document is a letter from the U.S. Department of Justice to the Honorable Alison J. Nathan regarding the case United States v. Ghislaine Maxwell. The letter discusses the deadline for filing a motion under Federal Rule of Evidence 412 and the Court's order regarding the same. The document is signed by Alison J. Nathan and dated October 15, 2021."
}