mirror-epstein-docs/results/IMAGES001/DOJ-OGR-00002262.json

{
  "document_metadata": {
    "page_number": "2",
    "document_number": "102",
    "date": "January 8, 2021",
    "document_type": "Court Document",
    "has_handwriting": true,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 102 Filed 01/08/21 Page 2 of 2\nThe Honorable Alison J. Nathan\nJanuary 8, 2021\nPage 2\nA brief extension of the time to appeal would also promote judicial efficiency because a third bail application may moot the need to appeal from the December 28 Order (or, in the event the third application is denied, permit a consolidated appeal). Conversely, denying the extension will require Ms. Maxwell to file a notice of appeal on January 11, 2021, which may lead to unnecessary parallel proceedings in this Court and in the Court of Appeals.\nWe have conferred with the government and it objects to the requested extension.\nFor these reasons, we respectfully request that the Court grant a 30-day extension of time under Rule 4(b)(4) of the Federal Rules of Appellate Procedure to file our notice of appeal of the Court's order denying Ms. Maxwell's renewed motion for bail. (Dkt. 104, 106).1\nSO ORDERED.\nSincerely,\n/s/ Christian Everdell\nChristian R. Everdell\nCOHEN & GRESSER LLP\n800 Third Avenue, 21st Floor\nNew York, New York 10022\n(212) 957-7600\nThe request is denied. Good cause for an extension of time to file a notice of appeal has not been provided.\nSO ORDERED.\n1/11/21\nAlison J. Nathan\nUnited States District Judge\ncc: All Counsel of Record (By ECF)\n1 In the event this motion is denied (or not granted by the close of business on January 11, 2021), Ms. Maxwell will file a notice of appeal to preserve her right to appeal the December 28, 2020 Order denying the renewed motion for bail (Dkt. 104, 106).",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 102 Filed 01/08/21 Page 2 of 2",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "The Honorable Alison J. Nathan\nJanuary 8, 2021\nPage 2",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "A brief extension of the time to appeal would also promote judicial efficiency because a third bail application may moot the need to appeal from the December 28 Order (or, in the event the third application is denied, permit a consolidated appeal). Conversely, denying the extension will require Ms. Maxwell to file a notice of appeal on January 11, 2021, which may lead to unnecessary parallel proceedings in this Court and in the Court of Appeals.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "We have conferred with the government and it objects to the requested extension.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "For these reasons, we respectfully request that the Court grant a 30-day extension of time under Rule 4(b)(4) of the Federal Rules of Appellate Procedure to file our notice of appeal of the Court's order denying Ms. Maxwell's renewed motion for bail. (Dkt. 104, 106).1\nSO ORDERED.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Sincerely,",
      "position": "body"
    },
    {
      "type": "signature",
      "content": "/s/ Christian Everdell",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Christian R. Everdell\nCOHEN & GRESSER LLP\n800 Third Avenue, 21st Floor\nNew York, New York 10022\n(212) 957-7600",
      "position": "footer"
    },
    {
      "type": "handwritten",
      "content": "The request is denied. Good cause for an extension of time to file a notice of appeal has not been provided.\nSO ORDERED.",
      "position": "margin"
    },
    {
      "type": "handwritten",
      "content": "1/11/21",
      "position": "margin"
    },
    {
      "type": "signature",
      "content": "Alison J. Nathan",
      "position": "margin"
    },
    {
      "type": "printed",
      "content": "United States District Judge",
      "position": "margin"
    },
    {
      "type": "printed",
      "content": "cc: All Counsel of Record (By ECF)",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "1 In the event this motion is denied (or not granted by the close of business on January 11, 2021), Ms. Maxwell will file a notice of appeal to preserve her right to appeal the December 28, 2020 Order denying the renewed motion for bail (Dkt. 104, 106).",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Christian Everdell",
      "Ms. Maxwell"
    ],
    "organizations": [
      "COHEN & GRESSER LLP",
      "Court of Appeals"
    ],
    "locations": [
      "New York"
    ],
    "dates": [
      "January 8, 2021",
      "January 11, 2021",
      "December 28, 2020"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "Document 102",
      "Dkt. 104",
      "Dkt. 106"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a bail application. It includes a request for an extension of time to file a notice of appeal and a response from the judge denying the request. The document is signed by Christian Everdell and includes a handwritten note from Judge Alison J. Nathan."
}