mirror-epstein-docs/results/IMAGES008/DOJ-OGR-00020608.json

{
  "document_metadata": {
    "page_number": "3",
    "document_number": "43",
    "date": "01/16/2023",
    "document_type": "Court Document",
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  "full_text": "Case 22-1426, Document 43, 01/16/2023, 3452785, Page3 of 4\n\n8. We request that the Court permit us to file a brief of no more than 20,000 words for the following reasons.\n\n9. We plan to raise issues concerning evidentiary rulings by the trial court that we believe were erroneous. The rulings at issue require a detailed discussion of the evidence. The transcript is over 3000 pages and contains the allegations of multiple complainants. The legal issues cannot be raised by reference to a few discrete pages of the transcript; rather they go to cumulative prejudice resulting from the trial court's erroneous application of the Federal Rules of Evidence to the case.\n\n10. In addition, we plan to raise issues pertaining to juror misconduct. This issue involves an exposition of facts and legal analysis pertaining to a juror questionnaire, voir dire, and a post-verdict hearing. It is, in itself, its own mini-trial.\n\n11. We also intend to raise issues pertaining to a non-prosecution agreement; certain instructions to the jury; and sentencing.\n\n12. A motion to file an oversized brief must be made no less than 14 days before the brief is due. Local Rule 27.1(e)3. Thus, we make this motion now, although our motion to extend time to file our brief is pending.\n\n13. We have notified Appellee United States Attorney's Office for the Southern District of New York today, by email to Assistant United States Attorneys Andrew Rohrbach, Lara Pomerantz, Alison Moe, and Maureen Comey, that we are making this motion and have asked their position and if they intend to file a response. We have not received a reply as of the time of filing.\n\n14. For the reasons stated, we respectfully request that the Court permit us to file a principal brief of no more than 20,000 words and would consent to Appellee filing a brief of\n\n2\n\nDOJ-OGR-00020608",
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      "content": "Case 22-1426, Document 43, 01/16/2023, 3452785, Page3 of 4",
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      "content": "8. We request that the Court permit us to file a brief of no more than 20,000 words for the following reasons.\n\n9. We plan to raise issues concerning evidentiary rulings by the trial court that we believe were erroneous. The rulings at issue require a detailed discussion of the evidence. The transcript is over 3000 pages and contains the allegations of multiple complainants. The legal issues cannot be raised by reference to a few discrete pages of the transcript; rather they go to cumulative prejudice resulting from the trial court's erroneous application of the Federal Rules of Evidence to the case.\n\n10. In addition, we plan to raise issues pertaining to juror misconduct. This issue involves an exposition of facts and legal analysis pertaining to a juror questionnaire, voir dire, and a post-verdict hearing. It is, in itself, its own mini-trial.\n\n11. We also intend to raise issues pertaining to a non-prosecution agreement; certain instructions to the jury; and sentencing.\n\n12. A motion to file an oversized brief must be made no less than 14 days before the brief is due. Local Rule 27.1(e)3. Thus, we make this motion now, although our motion to extend time to file our brief is pending.\n\n13. We have notified Appellee United States Attorney's Office for the Southern District of New York today, by email to Assistant United States Attorneys Andrew Rohrbach, Lara Pomerantz, Alison Moe, and Maureen Comey, that we are making this motion and have asked their position and if they intend to file a response. We have not received a reply as of the time of filing.\n\n14. For the reasons stated, we respectfully request that the Court permit us to file a principal brief of no more than 20,000 words and would consent to Appellee filing a brief of",
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      "content": "DOJ-OGR-00020608",
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  "entities": {
    "people": [
      "Andrew Rohrbach",
      "Lara Pomerantz",
      "Alison Moe",
      "Maureen Comey"
    ],
    "organizations": [
      "United States Attorney's Office",
      "Southern District of New York"
    ],
    "locations": [
      "New York"
    ],
    "dates": [
      "01/16/2023"
    ],
    "reference_numbers": [
      "Case 22-1426",
      "Document 43",
      "3452785",
      "DOJ-OGR-00020608"
    ]
  },
  "additional_notes": "The document appears to be a court filing with a clear and legible format. There are no visible redactions or damage to the document."
}