mirror-epstein-docs/results/IMAGES004/DOJ-OGR-00011342.json

{
  "document_metadata": {
    "page_number": "1 of 3",
    "document_number": "720",
    "date": "07/12/22",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 720 Filed 07/12/22 Page 1 of 3\nCOHEN & GRESSER LLP\n800 Third Avenue\nNew York, NY 10022\n+1 212 957 7600 phone\nwww.cohengresser.com\nChristian R. Everdell\n+1 (212) 957-7600\nceverdell@cohengresser.com\nDecember 14, 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, NY 10007\nRe: United States v. Ghislaine Maxwell, S2 20 Cr. 330 (AJN)\nDear Judge Nathan:\nPursuant to the Court's Order of earlier today (Dkt. 542), we write to provide the Court and the government with a revised tentative order of the defense witnesses. We note the following:\n1. We are still trying to make travel arrangements for the defense witnesses, many of whom are coming from locations all over the United States and from the United Kingdom. Accordingly, the order below is subject to change. We are making every effort to have witnesses available for Thursday and Friday but, in an abundance of caution, we are informing the Court and counsel that travel and COVID-related issues may require the case to be continued to next week.\n2. The list of witnesses may be substantially reduced if the government is willing to agree to stipulations as to certain documents and witness testimony. We have conferred with the government regarding these stipulations, but as yet the government has not agreed to them. Accordingly, the list includes several witnesses who will be called to introduce certain documents or to testify about particular prior inconsistent statements.\n2064893.1\nDOJ-OGR-00011342",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 720 Filed 07/12/22 Page 1 of 3",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "COHEN & GRESSER LLP\n800 Third Avenue\nNew York, NY 10022\n+1 212 957 7600 phone\nwww.cohengresser.com",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Christian R. Everdell\n+1 (212) 957-7600\nceverdell@cohengresser.com",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "December 14, 2021",
      "position": "top"
    },
    {
      "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, NY 10007",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Re: United States v. Ghislaine Maxwell, S2 20 Cr. 330 (AJN)",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Dear Judge Nathan:",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Pursuant to the Court's Order of earlier today (Dkt. 542), we write to provide the Court and the government with a revised tentative order of the defense witnesses. We note the following:",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "1. We are still trying to make travel arrangements for the defense witnesses, many of whom are coming from locations all over the United States and from the United Kingdom. Accordingly, the order below is subject to change. We are making every effort to have witnesses available for Thursday and Friday but, in an abundance of caution, we are informing the Court and counsel that travel and COVID-related issues may require the case to be continued to next week.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "2. The list of witnesses may be substantially reduced if the government is willing to agree to stipulations as to certain documents and witness testimony. We have conferred with the government regarding these stipulations, but as yet the government has not agreed to them. Accordingly, the list includes several witnesses who will be called to introduce certain documents or to testify about particular prior inconsistent statements.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "2064893.1\nDOJ-OGR-00011342",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Christian R. Everdell",
      "Alison J. Nathan",
      "Ghislaine Maxwell"
    ],
    "organizations": [
      "COHEN & GRESSER LLP",
      "United States District Court",
      "United States Courthouse"
    ],
    "locations": [
      "New York",
      "United States",
      "United Kingdom"
    ],
    "dates": [
      "December 14, 2021",
      "07/12/22"
    ],
    "reference_numbers": [
      "Dkt. 542",
      "S2 20 Cr. 330 (AJN)",
      "2064893.1",
      "DOJ-OGR-00011342"
    ]
  },
  "additional_notes": "The document appears to be a letter from Christian R. Everdell to Judge Alison J. Nathan regarding the case United States v. Ghislaine Maxwell. The letter is typed and appears to be in good condition."
}