mirror-epstein-docs/results/IMAGES004/DOJ-OGR-00009622.json

{
  "document_metadata": {
    "page_number": "1",
    "document_number": "63207",
    "date": "March 2, 2022",
    "document_type": "Letter",
    "has_handwriting": true,
    "has_stamps": true
  },
  "full_text": "Case#: 2020cr00303(PaN Document#: 63207 Filed03/03/22 Pa9e1lof2\nHaddon, Morgan and Foreman, P.C\nJeffrey S. Pagliuca\n950 17th Street\nSuite 1000\nDenver, Colorado 80202\nPH 303.831.7364\nFX 303.832.2628\nwww.hmflaw.com\njpagliuca@hmflaw.com\nUSDC SDNY\nDOCUMENT\nELECTRONICALLY FILED\nDOC#:\nDATE FILED: 3/3/22\nMarch 2, 2022\nVIA EMAIL\nThe Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\n40 Foley Square\nNew York, NY 10007\nRe: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)\nMaxwell Request for adjournment of hearing on Motion for New Trial\nDear Judge Nathan,\nMs. Maxwell respectfully requests that the Court continue the hearing scheduled to occur on March 8, 2021. Unfortunately, Ms. Maxwell's Colorado based counsel are unavailable.\nMr. Pagliuca will be in a criminal jury trial in Eagle County Colorado, People v. Robert Fergus-Jean, 2020 CR 000304. Both sides announced ready on February 9, 2022. The trial will begin on March 7 and will last approximately 10 days. Ms. Menninger is and unavailable to travel to New York\nOn March 16, 2022, Ms. Sternheim starts a trial, of approximately six-week duration, before the Honorable Jesse M. Furman in United States v. Marquez-Alejandro and Blondet, 16 Cr. 387 (JMF), the trial that was rescheduled to accommodate commencement of Ms. Maxwell's trial last November.\nThe requested two-month adjournment to May is not justified and is therefore DENIED. Two of the Defendant's four attorneys are able to be present and represent the Defendant at the March 8 hearing. The Court will conduct the questioning at the hearing, and the parties have already submitted briefing and proposed questions. The public interest in a reasonably prompt hearing outweighs the Defendant's preference for an adjournment. SO ORDERED.\nAlison J. Nathan\n3/3/22",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case#: 2020cr00303(PaN Document#: 63207 Filed03/03/22 Pa9e1lof2",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Haddon, Morgan and Foreman, P.C\nJeffrey S. Pagliuca\n950 17th Street\nSuite 1000\nDenver, Colorado 80202\nPH 303.831.7364\nFX 303.832.2628\nwww.hmflaw.com\njpagliuca@hmflaw.com",
      "position": "header"
    },
    {
      "type": "stamp",
      "content": "USDC SDNY\nDOCUMENT\nELECTRONICALLY FILED\nDOC#:\nDATE FILED: 3/3/22",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "March 2, 2022\nVIA EMAIL\nThe Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\n40 Foley Square\nNew York, NY 10007",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)\nMaxwell Request for adjournment of hearing on Motion for New Trial",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Dear Judge Nathan,\nMs. Maxwell respectfully requests that the Court continue the hearing scheduled to occur on March 8, 2021. Unfortunately, Ms. Maxwell's Colorado based counsel are unavailable.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Mr. Pagliuca will be in a criminal jury trial in Eagle County Colorado, People v. Robert Fergus-Jean, 2020 CR 000304. Both sides announced ready on February 9, 2022. The trial will begin on March 7 and will last approximately 10 days. Ms. Menninger is and unavailable to travel to New York",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "On March 16, 2022, Ms. Sternheim starts a trial, of approximately six-week duration, before the Honorable Jesse M. Furman in United States v. Marquez-Alejandro and Blondet, 16 Cr. 387 (JMF), the trial that was rescheduled to accommodate commencement of Ms. Maxwell's trial last November.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The requested two-month adjournment to May is not justified and is therefore DENIED. Two of the Defendant's four attorneys are able to be present and represent the Defendant at the March 8 hearing. The Court will conduct the questioning at the hearing, and the parties have already submitted briefing and proposed questions. The public interest in a reasonably prompt hearing outweighs the Defendant's preference for an adjournment. SO ORDERED.",
      "position": "middle"
    },
    {
      "type": "signature",
      "content": "Alison J. Nathan",
      "position": "bottom"
    },
    {
      "type": "handwritten",
      "content": "3/3/22",
      "position": "bottom"
    }
  ],
  "entities": {
    "people": [
      "Jeffrey S. Pagliuca",
      "Alison J. Nathan",
      "Ghislaine Maxwell",
      "Robert Fergus-Jean",
      "Jesse M. Furman",
      "Marquez-Alejandro",
      "Blondet",
      "Ms. Menninger",
      "Ms. Sternheim"
    ],
    "organizations": [
      "Haddon, Morgan and Foreman, P.C",
      "United States District Court",
      "Southern District of New York"
    ],
    "locations": [
      "Denver",
      "Colorado",
      "New York",
      "Eagle County"
    ],
    "dates": [
      "March 2, 2022",
      "March 8, 2021",
      "February 9, 2022",
      "March 7",
      "March 16, 2022",
      "May",
      "November"
    ],
    "reference_numbers": [
      "20 Cr. 330 (AJN)",
      "2020 CR 000304",
      "16 Cr. 387 (JMF)"
    ]
  },
  "additional_notes": "The document appears to be a letter from Jeffrey S. Pagliuca to Judge Alison J. Nathan regarding a request for adjournment of a hearing in the case United States v. Ghislaine Maxwell. The letter is typed with a handwritten date and signature. There is a stamp indicating that the document was electronically filed with the USDC SDNY."
}