mirror-epstein-docs/results/IMAGES008/DOJ-OGR-00020603.json

{
  "document_metadata": {
    "page_number": "2",
    "document_number": "40",
    "date": "01/12/2023",
    "document_type": "Court Document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 22-1426, Document 40, 01/12/2023, 3451920, Page2 of 4\n\nUNITED STATES COURT OF APPEALS\nSECOND CIRCUIT\n\nUNITED STATES OF AMERICA,\nAppellee,\n\n- against -\n\nGHISLAINE MAXWELL,\nDefendant-Appellant.\n\nDocket No.: 22-1426\n\nAFFIRMATION IN\nSUPPORT OF\nDEFENDANT-\nAPPELLANT'S\nMOTION TO EXTEND\nTIME TO FILE BRIEF\n\nX\n\nJOHN M. LEVENTHAL, an attorney duly admitted to practice law in the State of New York and a partner of the law firm of AIDALA, BERTUNA & KAMINS PC., attorneys for Defendant-Appellant, GHISLAINE MAXWELL, hereby affirms the following statements, under penalties of perjury:\n\n1. That I am a partner at the law firm of AIDALA, BERTUNA & KAMINS P.C., attorneys for Defendant-Appellant, Ghislaine Maxwell (hereinafter \"Appellant\"), and as such, am fully familiar with the facts and circumstances of this action.\n\n3. On July 15, 2022, I filed a Notice of Appearance in this matter so that trial counsel could withdraw.\n\n4. On July 28, 2022, I filed a scheduling request asking that Appellant's brief be due on January 30, 2023, based on the size of the record.\n\n5. Soon after this Court granted our scheduling request, we were notified that the New York Court of Appeals had granted us leave on another matter which also involved a voluminous record and several issues of law which required substantial time and resources.\n\n6. The work of our small team of experienced appellate attorneys has been divided between these two cases. In addition, one of our appellate attorneys is dealing with a serious health condition. This has impacted his ability to work on the case.\n\n7. Another factor that has affected our ability to complete this brief by the current\n\n1\n\nDOJ-OGR-00020603",
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      "content": "Case 22-1426, Document 40, 01/12/2023, 3451920, Page2 of 4",
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    {
      "type": "printed",
      "content": "UNITED STATES COURT OF APPEALS\nSECOND CIRCUIT",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "UNITED STATES OF AMERICA,\nAppellee,\n\n- against -\n\nGHISLAINE MAXWELL,\nDefendant-Appellant.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Docket No.: 22-1426",
      "position": "margin"
    },
    {
      "type": "printed",
      "content": "AFFIRMATION IN\nSUPPORT OF\nDEFENDANT-\nAPPELLANT'S\nMOTION TO EXTEND\nTIME TO FILE BRIEF",
      "position": "margin"
    },
    {
      "type": "printed",
      "content": "JOHN M. LEVENTHAL, an attorney duly admitted to practice law in the State of New York and a partner of the law firm of AIDALA, BERTUNA & KAMINS PC., attorneys for Defendant-Appellant, GHISLAINE MAXWELL, hereby affirms the following statements, under penalties of perjury:",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "1. That I am a partner at the law firm of AIDALA, BERTUNA & KAMINS P.C., attorneys for Defendant-Appellant, Ghislaine Maxwell (hereinafter \"Appellant\"), and as such, am fully familiar with the facts and circumstances of this action.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "3. On July 15, 2022, I filed a Notice of Appearance in this matter so that trial counsel could withdraw.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "4. On July 28, 2022, I filed a scheduling request asking that Appellant's brief be due on January 30, 2023, based on the size of the record.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "5. Soon after this Court granted our scheduling request, we were notified that the New York Court of Appeals had granted us leave on another matter which also involved a voluminous record and several issues of law which required substantial time and resources.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "6. The work of our small team of experienced appellate attorneys has been divided between these two cases. In addition, one of our appellate attorneys is dealing with a serious health condition. This has impacted his ability to work on the case.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "7. Another factor that has affected our ability to complete this brief by the current",
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    },
    {
      "type": "printed",
      "content": "1",
      "position": "footer"
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    {
      "type": "printed",
      "content": "DOJ-OGR-00020603",
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  ],
  "entities": {
    "people": [
      "JOHN M. LEVENTHAL",
      "GHISLAINE MAXWELL"
    ],
    "organizations": [
      "AIDALA, BERTUNA & KAMINS PC",
      "UNITED STATES COURT OF APPEALS",
      "New York Court of Appeals"
    ],
    "locations": [
      "New York"
    ],
    "dates": [
      "01/12/2023",
      "July 15, 2022",
      "July 28, 2022",
      "January 30, 2023"
    ],
    "reference_numbers": [
      "22-1426",
      "DOJ-OGR-00020603"
    ]
  },
  "additional_notes": "The document appears to be a court filing with no visible redactions or damage."
}