mirror-epstein-docs/results/IMAGES003/DOJ-OGR-00006201.json

{
  "document_metadata": {
    "page_number": "1",
    "document_number": "423",
    "date": "11/08/2021",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 423 Filed 11/08/21 Page 1 of 11\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\nNovember 8, 2021\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 opposition to the defendant's motion to reconsider this Court's prior bail determinations. (Dkt. 408 (\"Def. Mot.\")). This Court has repeatedly found that there are no conditions of release that can reasonably assure the defendant's appearance (Dkt. 93, 106, 169), and the Second Circuit has twice rejected the defendant's appeals (see United States v. Maxwell, No. 21-58, Dkt. 86, 96 (2d Cir.)). The defendant's latest motion largely repeats arguments that have been made and rejected before. There is no basis for the Court to reconsider its prior rulings.\nA. Procedural History\n1. The Court's First Detention Order\nAfter the defendant's arrest, this Court received multiple written submissions and held a lengthy oral argument on the question of bail. (See Dkt. 93 (\"First Order\")). On July 14, 2020, in a detailed oral ruling, the Court ordered the defendant detained on the basis of risk of flight. (Id. at 79-91). First, the Court found that \"the nature and circumstances of the offense here weigh in favor of detention,\" given the statutory presumption of detention triggered by charges involving",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 423 Filed 11/08/21 Page 1 of 11",
      "position": "header"
    },
    {
      "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": "November 8, 2021",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "BY ECF",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The 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": "top"
    },
    {
      "type": "printed",
      "content": "Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Dear Judge Nathan:",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The Government respectfully submits this letter in opposition to the defendant's motion to reconsider this Court's prior bail determinations. (Dkt. 408 (\"Def. Mot.\")). This Court has repeatedly found that there are no conditions of release that can reasonably assure the defendant's appearance (Dkt. 93, 106, 169), and the Second Circuit has twice rejected the defendant's appeals (see United States v. Maxwell, No. 21-58, Dkt. 86, 96 (2d Cir.)). The defendant's latest motion largely repeats arguments that have been made and rejected before. There is no basis for the Court to reconsider its prior rulings.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "A. Procedural History",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "1. The Court's First Detention Order",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "After the defendant's arrest, this Court received multiple written submissions and held a lengthy oral argument on the question of bail. (See Dkt. 93 (\"First Order\")). On July 14, 2020, in a detailed oral ruling, the Court ordered the defendant detained on the basis of risk of flight. (Id. at 79-91). First, the Court found that \"the nature and circumstances of the offense here weigh in favor of detention,\" given the statutory presumption of detention triggered by charges involving",
      "position": "middle"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ghislaine Maxwell"
    ],
    "organizations": [
      "U.S Department of Justice",
      "United States Attorney",
      "United States District Court",
      "Second Circuit"
    ],
    "locations": [
      "New York",
      "Southern District of New York"
    ],
    "dates": [
      "November 8, 2021",
      "July 14, 2020"
    ],
    "reference_numbers": [
      "Case 1:20-cr-00330-PAE",
      "Document 423",
      "20 Cr. 330 (AJN)",
      "Dkt. 408",
      "Dkt. 93",
      "Dkt. 106",
      "Dkt. 169",
      "No. 21-58",
      "Dkt. 86",
      "Dkt. 96"
    ]
  },
  "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 typed and contains legal language and references to specific court documents."
}