mirror-epstein-docs/results/IMAGES007/DOJ-OGR-00020313.json

{
  "document_metadata": {
    "page_number": "7",
    "document_number": "Case 1:20-cr-00330-AJ Document 19 Filed 03/19/21 Page 7 of 8",
    "date": "March 19, 2021",
    "document_type": "Legal Document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "government in person to confer on a briefing schedule for supplemental pretrial motions, as well as other deadlines, which we are prepared to discuss with the Court at the arraignment.\n\nThe government's revised trial estimate from two to four weeks remains unrealistic and does not include jury selection, which will take longer than usual in this media-saturated case.\n\nWe oppose advancing jury selection beyond early distribution of questionnaires to prospective jurors. Even if the case were tried on the previous indictment on July 12th, carving off any time required for trial preparation is unwarranted and unfair.\n\nA continuance is justified based on the second superseding indictment. The new charges up the ante and double Ms. Maxwell's sentencing exposure. To deny her a continuance undercuts her constitutional right to a fair trial and effective assistance of counsel. A continuance - the need for which is caused solely by the government - is reasonable and necessary in defense of Ms. Maxwell. The denial of a continuance risks a miscarriage of justice.\n\nDespite Its Necessity, A Continuance Further Prejudices Ms. Maxwell\n\nA delay of the July 12th trial - especially one that accommodates counsel's other trial schedules - has a direct and deleterious impact on Ms. Maxwell as a result of her continued detention, the details of which are well known to the Court. In addition to her prolonged detention, she is the victim on ongoing hostile media reporting which impacts the ability to seat fair and impartial jurors.\n\nOn April 26th, Second Circuit will hear oral argument on Ms. Maxwell's bail appeal and may moot any need for a further bail application. Nonetheless, Ms. Maxwell reserves her right to seek a bail hearing depending on the Circuit's decision.",
  "text_blocks": [
    {
      "type": "printed",
      "content": "government in person to confer on a briefing schedule for supplemental pretrial motions, as well as other deadlines, which we are prepared to discuss with the Court at the arraignment.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The government's revised trial estimate from two to four weeks remains unrealistic and does not include jury selection, which will take longer than usual in this media-saturated case.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "We oppose advancing jury selection beyond early distribution of questionnaires to prospective jurors. Even if the case were tried on the previous indictment on July 12th, carving off any time required for trial preparation is unwarranted and unfair.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "A continuance is justified based on the second superseding indictment. The new charges up the ante and double Ms. Maxwell's sentencing exposure. To deny her a continuance undercuts her constitutional right to a fair trial and effective assistance of counsel. A continuance - the need for which is caused solely by the government - is reasonable and necessary in defense of Ms. Maxwell. The denial of a continuance risks a miscarriage of justice.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Despite Its Necessity, A Continuance Further Prejudices Ms. Maxwell",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "A delay of the July 12th trial - especially one that accommodates counsel's other trial schedules - has a direct and deleterious impact on Ms. Maxwell as a result of her continued detention, the details of which are well known to the Court. In addition to her prolonged detention, she is the victim on ongoing hostile media reporting which impacts the ability to seat fair and impartial jurors.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "On April 26th, Second Circuit will hear oral argument on Ms. Maxwell's bail appeal and may moot any need for a further bail application. Nonetheless, Ms. Maxwell reserves her right to seek a bail hearing depending on the Circuit's decision.",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00020313",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Ms. Maxwell",
      "Bobbi C. Sternheim"
    ],
    "organizations": [
      "LAW OFFICES OF BOBBI C. STERNHEIM",
      "Second Circuit",
      "Court"
    ],
    "locations": [],
    "dates": [
      "July 12th",
      "April 26th",
      "March 19, 2021"
    ],
    "reference_numbers": [
      "Case 1:20-cr-00330-AJ Document 19",
      "DOJ-OGR-00020313"
    ]
  },
  "additional_notes": "The document appears to be a legal filing related to the case of Ms. Maxwell. It is typed and has a formal tone. The content discusses the need for a continuance in the trial due to the second superseding indictment and its impact on Ms. Maxwell's sentencing exposure and detention."
}