mirror-epstein-docs/results/IMAGES004/DOJ-OGR-00010592.json

{
  "document_metadata": {
    "page_number": "1 of 68",
    "document_number": "672",
    "date": "06/24/22",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 672 Filed 06/24/22 Page 1 of 68 LAW OFFICES OF BOBBI C. STERNHEIM 212-243-1100 * Main 917-912-9698 * Cell 888-587-4737 * Fax 225 Broadway, Suite 715 New York, NY 10007 bcsternheim@mac.com June 24, 2022 Submission Under Seal Honorable Alison J. Nathan Sitting By Designation United States District Court 40 Foley Square New York, NY 10007 Re: United States v. Ghislaine Maxwell S2 20 Cr. 330 (AJN) Dear Judge Nathan: Ghislaine Maxwell submits this letter in response to the Court's order (Dkt. 665). Ms. Maxwell objects to characterization of Sarah Ransome, Maria Farmer, Teresa Helm, and Juliette Bryant (collectively, the \"Individuals\") as \"victims\" of the counts of conviction and disputes that the Individuals qualify as statutory victims within the definition of a \"crime victim\" contained in the Crime Victims' Rights Act, 18 U.S.C.A. §3771 (\"CVRA\"). The issue that requires resolution in advance of sentencing is whether the Individuals, or their representatives, have statutory crime victim status under the CVRA. Under the statute, definition of \"crime victim\" takes as a given that there has been a \"federal offense\" committed. See 18 U.S.C. § 3771(e)(2)(A). Ms. Maxwell asserts that the Individuals are not statutory crime victims of the federal offenses of conviction, which require that (i) each was a minor at the time to the alleged abuse, (ii) the alleged abuse occurred during the period alleged in the indictment, and (iii) the Individuals were \"directly and proximately harmed as a result of the commission of [the] Federal offense.\" Id.(emphasis added). DOJ-OGR-00010592",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 672 Filed 06/24/22 Page 1 of 68",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "LAW OFFICES OF BOBBI C. STERNHEIM",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "212-243-1100 * Main 917-912-9698 * Cell 888-587-4737 * Fax 225 Broadway, Suite 715 New York, NY 10007 bcsternheim@mac.com",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "June 24, 2022",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Submission Under Seal",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Honorable Alison J. Nathan Sitting By Designation United States District Court 40 Foley Square New York, NY 10007",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Re: United States v. Ghislaine Maxwell S2 20 Cr. 330 (AJN)",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Dear Judge Nathan: Ghislaine Maxwell submits this letter in response to the Court's order (Dkt. 665). Ms. Maxwell objects to characterization of Sarah Ransome, Maria Farmer, Teresa Helm, and Juliette Bryant (collectively, the \"Individuals\") as \"victims\" of the counts of conviction and disputes that the Individuals qualify as statutory victims within the definition of a \"crime victim\" contained in the Crime Victims' Rights Act, 18 U.S.C.A. §3771 (\"CVRA\").",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The issue that requires resolution in advance of sentencing is whether the Individuals, or their representatives, have statutory crime victim status under the CVRA. Under the statute, definition of \"crime victim\" takes as a given that there has been a \"federal offense\" committed. See 18 U.S.C. § 3771(e)(2)(A). Ms. Maxwell asserts that the Individuals are not statutory crime victims of the federal offenses of conviction, which require that (i) each was a minor at the time to the alleged abuse, (ii) the alleged abuse occurred during the period alleged in the indictment, and (iii) the Individuals were \"directly and proximately harmed as a result of the commission of [the] Federal offense.\" Id.(emphasis added).",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00010592",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ghislaine Maxwell",
      "Sarah Ransome",
      "Maria Farmer",
      "Teresa Helm",
      "Juliette Bryant"
    ],
    "organizations": [
      "Law Offices of Bobbi C. Sternheim",
      "United States District Court"
    ],
    "locations": [
      "New York",
      "NY",
      "Broadway"
    ],
    "dates": [
      "June 24, 2022",
      "06/24/22"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 672",
      "S2 20 Cr. 330 (AJN)",
      "Dkt. 665",
      "DOJ-OGR-00010592"
    ]
  },
  "additional_notes": "The document appears to be a formal legal letter, with no visible redactions or damage."
}