mirror-epstein-docs/results/IMAGES008/DOJ-OGR-00020596.json

{
  "document_metadata": {
    "page_number": "1",
    "document_number": "30",
    "date": "July 28, 2022",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 22-1426, Document 30, 07/28/2022, 3356263, Page 1 of 2\nAidala, Bertuna & Kamins, P.C.\nARTHUR L. AIDALA*\nMARIANNE E. BERTUNA*\nHON. BARRY KAMINS (RET.)\nHON. JOHN M. LEVENTHAL (RET.)\nJOHN S. ESPOSITO*\nMICHAEL T. JACCARINO\nIMRAN H. ANSARI\nDIANA FABI SAMSON**\nANDREA M. ARRIGO*\nLINO J. DE MASI\nMICHAEL F. DIBENEDETTO*\n*ALSO ADMITTED IN NEW JERSEY\n**ALSO ADMITTED IN CONNECTICUT\n546 FIFTH AVENUE\nNEW YORK, NY 10036\nTELEPHONE: (212) 486-0011\nFACSIMILE: (917) 261-4832\nWWW.AIDALALAW.COM\nJuly 28, 2022\n8118 - 13TH AVENUE\nBROOKLYN, NEW YORK 11228\nTEL: (718) 238-9898\nFAX: (718) 921-3292\nOF COUNSEL\nJOSEPH A. BARATTA\nANTOINETTE LANTERI\nWILLIAM R. SANTO\nPETER S. THOMAS\nLAWRENCE SPASOJEVICH\nSENIOR COUNSEL\nLOUIS R. AIDALA\nJOSEPH P. BARATTA\nCatherine O'Hagan Wolfe\nClerk of Court\nThurgood Marshall United States Court House\n40 Foley Square\nNew York, New York 10007\nRe: Briefing Schedule Request, USA v. Ghislaine Maxwell, Case 22-1426\nDear Ms. O'Hagan Wolfe,\nI am appellate counsel for Defendant-Appellant Ghislaine Maxwell. I was not trial counsel for Ms. Maxwell. I filed an Acknowledgement and Notice of Appearance on July 15, 2022. The Clerk required that I file a Form B on that date, as well, although I did not, at that time, have any information concerning the transcripts.\nPursuant to Local Rule 31.2(a)(1)(A), the ready date for this case was July 15, 2022. Accordingly, I have until July 29, 2022, to file this briefing schedule request. Pursuant to Local Rule 31.2(a)(1)(A), I can request no more than 91 days from the ready date as the deadline for filing Appellant's Brief. That date would be October 14, 2022.\nPursuant to Local Rule 31.2(a)(1)(D), however, I am permitted to request a later deadline to file Appellant's Brief if the case involves a voluminous record or extreme hardship would result. I request that the Court permit me to file Appellant's Brief on Monday, January 30, 2023, for the following reasons which I believe satisfy both preconditions identified by the rule. First, as noted, I am new counsel and have obtained access to the complete file on this case only this week. As new counsel unfamiliar with the case, I must therefore scrutinize the entire record in order to provide my client with the most competent and effective representation on appeal. Second, the record is voluminous in that it involves at least 3,824 pages of transcript including pretrial hearings, voir dire, trial, sentence, and post-conviction proceedings. In addition, the Docket Report consists of 738 entries, including but not limited to dozens of fully briefed pretrial motions and motions in limine, comprising hundreds of pages of legal analysis on important issues. Third, I must conduct my own research in order to determine what issues I believe provide my client with the best chance of prevailing on appeal. This is especially important given this Court's rules concerning the size of Appellant's Brief. Fourth, I have not been able to meet with my client as she was prematurely transferred to Tallahassee, Florida by the Federal Bureau of Prisons over this past weekend, a\nDOJ-OGR-00020596",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 22-1426, Document 30, 07/28/2022, 3356263, Page 1 of 2",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Aidala, Bertuna & Kamins, P.C.",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "ARTHUR L. AIDALA*\nMARIANNE E. BERTUNA*\nHON. BARRY KAMINS (RET.)\nHON. JOHN M. LEVENTHAL (RET.)\nJOHN S. ESPOSITO*\nMICHAEL T. JACCARINO\nIMRAN H. ANSARI\nDIANA FABI SAMSON**\nANDREA M. ARRIGO*\nLINO J. DE MASI\nMICHAEL F. DIBENEDETTO*\n*ALSO ADMITTED IN NEW JERSEY\n**ALSO ADMITTED IN CONNECTICUT",
      "position": "left margin"
    },
    {
      "type": "printed",
      "content": "546 FIFTH AVENUE\nNEW YORK, NY 10036\nTELEPHONE: (212) 486-0011\nFACSIMILE: (917) 261-4832\nWWW.AIDALALAW.COM",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "July 28, 2022",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "8118 - 13TH AVENUE\nBROOKLYN, NEW YORK 11228\nTEL: (718) 238-9898\nFAX: (718) 921-3292",
      "position": "right margin"
    },
    {
      "type": "printed",
      "content": "OF COUNSEL\nJOSEPH A. BARATTA\nANTOINETTE LANTERI\nWILLIAM R. SANTO\nPETER S. THOMAS\nLAWRENCE SPASOJEVICH\nSENIOR COUNSEL\nLOUIS R. AIDALA\nJOSEPH P. BARATTA",
      "position": "right margin"
    },
    {
      "type": "printed",
      "content": "Catherine O'Hagan Wolfe\nClerk of Court\nThurgood Marshall United States Court House\n40 Foley Square\nNew York, New York 10007",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Re: Briefing Schedule Request, USA v. Ghislaine Maxwell, Case 22-1426",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Dear Ms. O'Hagan Wolfe,\nI am appellate counsel for Defendant-Appellant Ghislaine Maxwell. I was not trial counsel for Ms. Maxwell. I filed an Acknowledgement and Notice of Appearance on July 15, 2022. The Clerk required that I file a Form B on that date, as well, although I did not, at that time, have any information concerning the transcripts.\nPursuant to Local Rule 31.2(a)(1)(A), the ready date for this case was July 15, 2022. Accordingly, I have until July 29, 2022, to file this briefing schedule request. Pursuant to Local Rule 31.2(a)(1)(A), I can request no more than 91 days from the ready date as the deadline for filing Appellant's Brief. That date would be October 14, 2022.\nPursuant to Local Rule 31.2(a)(1)(D), however, I am permitted to request a later deadline to file Appellant's Brief if the case involves a voluminous record or extreme hardship would result. I request that the Court permit me to file Appellant's Brief on Monday, January 30, 2023, for the following reasons which I believe satisfy both preconditions identified by the rule. First, as noted, I am new counsel and have obtained access to the complete file on this case only this week. As new counsel unfamiliar with the case, I must therefore scrutinize the entire record in order to provide my client with the most competent and effective representation on appeal. Second, the record is voluminous in that it involves at least 3,824 pages of transcript including pretrial hearings, voir dire, trial, sentence, and post-conviction proceedings. In addition, the Docket Report consists of 738 entries, including but not limited to dozens of fully briefed pretrial motions and motions in limine, comprising hundreds of pages of legal analysis on important issues. Third, I must conduct my own research in order to determine what issues I believe provide my client with the best chance of prevailing on appeal. This is especially important given this Court's rules concerning the size of Appellant's Brief. Fourth, I have not been able to meet with my client as she was prematurely transferred to Tallahassee, Florida by the Federal Bureau of Prisons over this past weekend, a",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00020596",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Arthur L. Aidala",
      "Marianne E. Bertuna",
      "Barry Kamins",
      "John M. Leventhal",
      "John S. Esposito",
      "Michael T. Jaccarino",
      "Imran H. Ansari",
      "Diana Fabi Samson",
      "Andrea M. Arrigo",
      "Lino J. De Masi",
      "Michael F. DiBenedetto",
      "Joseph A. Baratta",
      "Antoinette Lanteri",
      "William R. Santo",
      "Peter S. Thomas",
      "Lawrence Spasojevich",
      "Louis R. Aidala",
      "Joseph P. Baratta",
      "Catherine O'Hagan Wolfe",
      "Ghislaine Maxwell"
    ],
    "organizations": [
      "Aidala, Bertuna & Kamins, P.C.",
      "Thurgood Marshall United States Court House",
      "Federal Bureau of Prisons"
    ],
    "locations": [
      "New York",
      "New Jersey",
      "Connecticut",
      "Brooklyn",
      "Tallahassee, Florida"
    ],
    "dates": [
      "July 28, 2022",
      "July 15, 2022",
      "July 29, 2022",
      "October 14, 2022",
      "January 30, 2023"
    ],
    "reference_numbers": [
      "Case 22-1426",
      "Document 30",
      "3356263",
      "DOJ-OGR-00020596"
    ]
  },
  "additional_notes": "The document appears to be a letter from Aidala, Bertuna & Kamins, P.C. to the Clerk of Court, Catherine O'Hagan Wolfe, regarding a briefing schedule request in the case USA v. Ghislaine Maxwell, Case 22-1426. The letter is dated July 28, 2022, and is signed by the law firm. The document is well-formatted and legible, with no visible redactions or damage."
}