mirror-epstein-docs/results/IMAGES004/DOJ-OGR-00008918.json

{
  "document_metadata": {
    "page_number": "3 of 5",
    "document_number": "597",
    "date": "02/11/22",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 597 Filed 02/11/22 Page 3 of 5\nWINSTON & STRAWN LLP\nNorth America Europe Asia\n1901 L Street, NW\nWashington, DC 20036\nT +1 202 282 5000\nF +1 202 282 5100\nFebruary 9, 2022\nVIA ELECTRONIC MAIL\nHon. Alison J. Nathan\nUnited States District Court\nSouthern District of New York\n40 Foley Square, Room 2102\nNew York, NY 10007\nRe: United States v. Maxwell, No. 1:20-cr-00330-AJN\nDear Judge Nathan:\nWe write on behalf of our client, the National Association of Criminal Defense Lawyers (NACDL), regarding the above-referenced action pending before you. We respectfully request leave from the Court to file a brief amicus curiae on the issue of the impact of the post-trial revelations and admissions from Juror # 50 on whether the Defendant in this case received the guaranteed right to a fair trial and what relief is required. Specifically, NACDL would address the increased importance of written or oral voir dire in high-profile criminal cases and/or those with sensitive issues central to a case that could reflect a juror's bias or potential for extraneous issues being brought into jury deliberations, the impact of inaccurate answers to questions asked to expose potential bias for further questioning and the exercise of strikes, whether and when a court should consider the deliberateness in a potential juror providing inaccurate information and the process by which such issues should be explored once they have been disclosed.\nIn support of this request to file a brief amicus curiae, proposed amici state the following:\n1. NACDL is a nonprofit voluntary professional bar association made up of and working on behalf of criminal defense attorneys to ensure justice and due process for those accused of crime or misconduct.\nDOJ-OGR-00008918",
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      "content": "Case 1:20-cr-00330-PAE Document 597 Filed 02/11/22 Page 3 of 5",
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    {
      "type": "printed",
      "content": "WINSTON & STRAWN LLP\nNorth America Europe Asia\n1901 L Street, NW\nWashington, DC 20036\nT +1 202 282 5000\nF +1 202 282 5100",
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    },
    {
      "type": "printed",
      "content": "February 9, 2022",
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    {
      "type": "printed",
      "content": "VIA ELECTRONIC MAIL\nHon. Alison J. Nathan\nUnited States District Court\nSouthern District of New York\n40 Foley Square, Room 2102\nNew York, NY 10007",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Re: United States v. Maxwell, No. 1:20-cr-00330-AJN",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Dear Judge Nathan:\nWe write on behalf of our client, the National Association of Criminal Defense Lawyers (NACDL), regarding the above-referenced action pending before you. We respectfully request leave from the Court to file a brief amicus curiae on the issue of the impact of the post-trial revelations and admissions from Juror # 50 on whether the Defendant in this case received the guaranteed right to a fair trial and what relief is required. Specifically, NACDL would address the increased importance of written or oral voir dire in high-profile criminal cases and/or those with sensitive issues central to a case that could reflect a juror's bias or potential for extraneous issues being brought into jury deliberations, the impact of inaccurate answers to questions asked to expose potential bias for further questioning and the exercise of strikes, whether and when a court should consider the deliberateness in a potential juror providing inaccurate information and the process by which such issues should be explored once they have been disclosed.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "In support of this request to file a brief amicus curiae, proposed amici state the following:\n1. NACDL is a nonprofit voluntary professional bar association made up of and working on behalf of criminal defense attorneys to ensure justice and due process for those accused of crime or misconduct.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00008918",
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  ],
  "entities": {
    "people": [
      "Alison J. Nathan"
    ],
    "organizations": [
      "WINSTON & STRAWN LLP",
      "National Association of Criminal Defense Lawyers (NACDL)",
      "United States District Court",
      "Southern District of New York"
    ],
    "locations": [
      "New York",
      "Washington, DC"
    ],
    "dates": [
      "February 9, 2022",
      "02/11/22"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 597",
      "1:20-cr-00330-AJN",
      "DOJ-OGR-00008918"
    ]
  },
  "additional_notes": "The document is a formal letter from WINSTON & STRAWN LLP to Hon. Alison J. Nathan regarding the case United States v. Maxwell. The letter is typed and appears to be in good condition with no visible damage or redactions."
}