mirror-epstein-docs/results/IMAGES004/DOJ-OGR-00011421.json

{
  "document_metadata": {
    "page_number": "1",
    "document_number": "731-2",
    "date": "December 15, 2021",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "PANISH SHEA & BOYLE LLP December 15, 2021 VIA EMAIL The Honorable Alison J. Nathan United States District Court Southern District of New York 40 Foley Square New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: I am writing on behalf of witness Jane in regard to Ms. Maxwell's recent filing regarding her attorney Robert Glassman who represented her in her civil case against the Epstein Estate and Ms. Maxwell that settled over a year ago. Ms. Maxwell raises three areas that she wants to solicit testimony from Mr. Glassman. 1. The \"Help her case\" email Jane stands on the opposition she submitted on December 6, 2021 and the Government's opposition regarding that email. 2. The Lion King email As the Government points out, Jane was extensively cross-examined on this issue. Mr. Glassman would have nothing to add, and anything he could say would require him to disclose confidential information in violation of California Rule of Professional Conduct 1.6. 3. Settlement Demands to Ms. Maxwell and the EVCP 11111 Santa Monica Boulevard, Suite 700 • Los Angeles, California 90025 • 310.477.1700 phone • 310.477.1699 fax • www.psblaw.com DOJ-OGR-00011421",
  "text_blocks": [
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      "type": "printed",
      "content": "PANISH SHEA & BOYLE LLP",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "December 15, 2021",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "VIA EMAIL The Honorable Alison J. Nathan United States District Court Southern District of New York 40 Foley Square New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: I am writing on behalf of witness Jane in regard to Ms. Maxwell's recent filing regarding her attorney Robert Glassman who represented her in her civil case against the Epstein Estate and Ms. Maxwell that settled over a year ago. Ms. Maxwell raises three areas that she wants to solicit testimony from Mr. Glassman. 1. The \"Help her case\" email Jane stands on the opposition she submitted on December 6, 2021 and the Government's opposition regarding that email. 2. The Lion King email As the Government points out, Jane was extensively cross-examined on this issue. Mr. Glassman would have nothing to add, and anything he could say would require him to disclose confidential information in violation of California Rule of Professional Conduct 1.6. 3. Settlement Demands to Ms. Maxwell and the EVCP",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "11111 Santa Monica Boulevard, Suite 700 • Los Angeles, California 90025 • 310.477.1700 phone • 310.477.1699 fax • www.psblaw.com",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00011421",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ghislaine Maxwell",
      "Jane",
      "Robert Glassman"
    ],
    "organizations": [
      "PANISH SHEA & BOYLE LLP",
      "United States District Court",
      "Epstein Estate",
      "EVCP"
    ],
    "locations": [
      "New York",
      "Los Angeles",
      "California"
    ],
    "dates": [
      "December 15, 2021",
      "December 6, 2021"
    ],
    "reference_numbers": [
      "20 Cr. 330 (AJN)",
      "731-2",
      "DOJ-OGR-00011421"
    ]
  },
  "additional_notes": "The document is a letter from PANISH SHEA & BOYLE LLP to Judge Alison J. Nathan regarding the case United States v. Ghislaine Maxwell. The letter is dated December 15, 2021, and is on page 1 of 3."
}