mirror-epstein-docs/results/IMAGES004/DOJ-OGR-00011356.json

{
  "document_metadata": {
    "page_number": "1",
    "document_number": "722",
    "date": "December 15, 2021",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 722 Filed 07/12/22 Page 1 of 7\nHaddon, Morgan and Foreman, P.C\nJeffrey S. Pagliuca\n150 East 10th Avenue\nDenver, Colorado 80203\nPH 303.831.7364\nFX 303.832.2628\nwww.hmflaw.com\njpagliuca@hmflaw.com\nDecember 15, 2021\n\nVIA Email\nThe Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\n40 Foley Square\nNew York, NY 10007\n\nRe:    United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)\n\nDear Judge Nathan,\n\nI write to alert the Court and the government to the inconsistent statements Ms. Maxwell intends to prove up by extrinsic evidence during her case.\n\nMs. Maxwell conferred with the government about this issue. After conferral, and given the press of time, counsel concluded it was most efficient to provide this notice to the Court and the government and to allow the government to consider which other statements it would stipulate to in addition to those the parties have already agreed on.\n\nA. Jane Inconsistent Statements\n\n| Trial Testimony | 3500 material cite | 3500 quote |\n| --- | --- | --- |\n| 375:20 - 376:20 | 3509-008, p. 12, 4th paragraph, last sentence | From when Jane met Epstein to when she moved to New York she lived in the same house in Florida. This house was in a gated community called Bear Lakes. It was a 3 bedroom house. |\n| 447:2 - 447:20 | 3509-002, p. 1 | GM walked by w/ dog. JE came up to meet her. |\n\nDOJ-OGR-00011356",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 722 Filed 07/12/22 Page 1 of 7",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Haddon, Morgan and Foreman, P.C\nJeffrey S. Pagliuca\n150 East 10th Avenue\nDenver, Colorado 80203\nPH 303.831.7364\nFX 303.832.2628\nwww.hmflaw.com\njpagliuca@hmflaw.com",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "December 15, 2021",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "VIA 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)\n\nDear Judge Nathan,",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "I write to alert the Court and the government to the inconsistent statements Ms. Maxwell intends to prove up by extrinsic evidence during her case.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Ms. Maxwell conferred with the government about this issue. After conferral, and given the press of time, counsel concluded it was most efficient to provide this notice to the Court and the government and to allow the government to consider which other statements it would stipulate to in addition to those the parties have already agreed on.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "A. Jane Inconsistent Statements",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "| Trial Testimony | 3500 material cite | 3500 quote |\n| --- | --- | --- |\n| 375:20 - 376:20 | 3509-008, p. 12, 4th paragraph, last sentence | From when Jane met Epstein to when she moved to New York she lived in the same house in Florida. This house was in a gated community called Bear Lakes. It was a 3 bedroom house. |\n| 447:2 - 447:20 | 3509-002, p. 1 | GM walked by w/ dog. JE came up to meet her. |",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00011356",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ghislaine Maxwell",
      "Jeffrey S. Pagliuca",
      "Jane",
      "Epstein",
      "GM",
      "JE"
    ],
    "organizations": [
      "Haddon, Morgan and Foreman, P.C",
      "United States District Court",
      "Southern District of New York"
    ],
    "locations": [
      "Denver",
      "Colorado",
      "New York"
    ],
    "dates": [
      "December 15, 2021",
      "07/12/22"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 722",
      "20 Cr. 330 (AJN)",
      "DOJ-OGR-00011356"
    ]
  },
  "additional_notes": "The document appears to be a formal letter from a law firm to a judge regarding a court case. The letter is well-formatted and contains a table with specific details about inconsistent statements."
}