mirror-epstein-docs/results/IMAGES008/DOJ-OGR-00020613.json

{
  "document_metadata": {
    "page_number": "2",
    "document_number": "50",
    "date": "02/14/2023",
    "document_type": "Court Document",
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    "has_stamps": false
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  "full_text": "Case 22-1426, Document 50, 02/14/2023, 3469305, Page2 of 4\n\nmotion to file an oversized brief in which we estimated that we would need permission to file a brief of no more than 20,000 words to fully brief the issues for appeal.\n\n7. On January 17, 2023, the Court granted our motion for an enlargement of time to file Appellant's brief.\n\n8. On January 18, 2023, the Court granted our request to file a brief of no more than 20,000 words.\n\n9. We have completed a draft of our brief and are now in a more definite position to request from the Court an additional 15,000 words so that we be permitted to file a brief of no more than 35,000 words.\n\n10. Our brief contains five points. These points raise issues pertaining to statute of limitations; a non-prosecution agreement; juror misconduct and a post-verdict hearing; and sentence. Some of these issues involve detailed analysis of case law, statutory interpretation and legislative history, while others involve an explication of the evidence and procedural posture relevant to the issues raised. In an effort to shorten our brief, we have already omitted what was a lengthy summary of the evidence at trial in favor of marshalling only the evidence essential to an analysis of the issues being raised.\n\n11. 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\n12. For the reasons stated, we respectfully request that the Court permit us to file a principal brief of no more than 35,000 words and would consent to Appellee filing a brief of",
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      "content": "Case 22-1426, Document 50, 02/14/2023, 3469305, Page2 of 4",
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      "type": "printed",
      "content": "motion to file an oversized brief in which we estimated that we would need permission to file a brief of no more than 20,000 words to fully brief the issues for appeal.\n\n7. On January 17, 2023, the Court granted our motion for an enlargement of time to file Appellant's brief.\n\n8. On January 18, 2023, the Court granted our request to file a brief of no more than 20,000 words.\n\n9. We have completed a draft of our brief and are now in a more definite position to request from the Court an additional 15,000 words so that we be permitted to file a brief of no more than 35,000 words.\n\n10. Our brief contains five points. These points raise issues pertaining to statute of limitations; a non-prosecution agreement; juror misconduct and a post-verdict hearing; and sentence. Some of these issues involve detailed analysis of case law, statutory interpretation and legislative history, while others involve an explication of the evidence and procedural posture relevant to the issues raised. In an effort to shorten our brief, we have already omitted what was a lengthy summary of the evidence at trial in favor of marshalling only the evidence essential to an analysis of the issues being raised.\n\n11. 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\n12. For the reasons stated, we respectfully request that the Court permit us to file a principal brief of no more than 35,000 words and would consent to Appellee filing a brief of",
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      "content": "2",
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    {
      "type": "printed",
      "content": "DOJ-OGR-00020613",
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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": [
      "January 17, 2023",
      "January 18, 2023",
      "02/14/2023"
    ],
    "reference_numbers": [
      "22-1426",
      "50",
      "3469305"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a legal case, with a formal tone and language typical of legal documents. The text is well-formatted and easy to read, with numbered paragraphs and clear headings. There are no visible redactions or damages to the document."
}