mirror-epstein-docs/results/IMAGES008/DOJ-OGR-00021998.json

{
  "document_metadata": {
    "page_number": "1",
    "document_number": "22",
    "date": "01/28/20",
    "document_type": "Court Document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:19-cr-00830-AT Document 22 Filed 01/28/20 Page 1 of 3\nU.S. Department of Justice\nUnited States Attorney\nSouthern District of New York\nThe Silvio J. Mollo Building\nOne Saint Andrew's Plaza\nNew York, New York 10007\nJanuary 28, 2020\nBY ECF\nThe Honorable Analisa Torres\nUnited States District Judge\nSouthern District of New York\n500 Pearl Street\nNew York, New York 10007\nRe: United States v. Noel and Thomas, 19 Cr. 830 (AT)\nDear Judge Torres:\nThe Government respectfully writes in response to the defendants' letters of January 27, 2020, requesting at least a six-month adjournment of the trial date in the above-captioned case, which is currently scheduled to commence on April 20, 2020. The Government remains prepared to proceed to trial as scheduled. As is set forth more fully below, while the Government has no objection to a brief adjournment of the trial date subject to the Court's availability, the requested six-month adjournment is both unnecessary and unwarranted.\nBy way of background, as is set forth in the Indictment, the charges in this case relate to a period of just over 14 hours—from approximately 4:00 p.m. on August 9, 2019 to approximately 6:30 a.m. the following day, August 10, 2019. The Government has made three discovery productions—(1) the main production on December 31, 2019; (2) a small supplemental production on January 23, 2020; and (3) a reproduction of video surveillance footage with timestamps on January 24, 2020.1 While the December 31, 2019 discovery production consisted of a large number of pages of materials, many of those materials were produced principally in anticipation of defense requests and to help facilitate the very sort of broader investigation the defendants now claim they need to undertake. For example, the Government produced MCC video surveillance for a period of longer than one month (July 5, 2019 to August 12, 2019); count slips for nearly three weeks (July 23, 2019 to August 14, 2019); thirty-minute round reports for more than a month (July 1, 2019 to August 10, 2019); and materials relating to the events of July 23, 2019. Similarly, with respect to defendant Noel, the Government provided in discovery to her only a report from her cellphone, which consists of more than 20,000 pages, very few of which, if any, are relevant to the pending charges.\nFor substantially the same reasons, and as the Court is aware, the\n1 For the third production, the Government requested additional hard drives from defense counsel. To date, only Noel's counsel provided a hard drive to the Government, which the Government then loaded and returned to counsel. The Government stands ready to do the same for Thomas as soon as a hard drive is provided.\nDOJ-OGR-00021998",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:19-cr-00830-AT Document 22 Filed 01/28/20 Page 1 of 3",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "U.S. Department of Justice\nUnited States Attorney\nSouthern District of New York\nThe Silvio J. Mollo Building\nOne Saint Andrew's Plaza\nNew York, New York 10007\nJanuary 28, 2020",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "BY ECF",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The Honorable Analisa Torres\nUnited States District Judge\nSouthern District of New York\n500 Pearl Street\nNew York, New York 10007",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Re: United States v. Noel and Thomas, 19 Cr. 830 (AT)",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Dear Judge Torres:",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The Government respectfully writes in response to the defendants' letters of January 27, 2020, requesting at least a six-month adjournment of the trial date in the above-captioned case, which is currently scheduled to commence on April 20, 2020. The Government remains prepared to proceed to trial as scheduled. As is set forth more fully below, while the Government has no objection to a brief adjournment of the trial date subject to the Court's availability, the requested six-month adjournment is both unnecessary and unwarranted.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "By way of background, as is set forth in the Indictment, the charges in this case relate to a period of just over 14 hours—from approximately 4:00 p.m. on August 9, 2019 to approximately 6:30 a.m. the following day, August 10, 2019. The Government has made three discovery productions—(1) the main production on December 31, 2019; (2) a small supplemental production on January 23, 2020; and (3) a reproduction of video surveillance footage with timestamps on January 24, 2020.1 While the December 31, 2019 discovery production consisted of a large number of pages of materials, many of those materials were produced principally in anticipation of defense requests and to help facilitate the very sort of broader investigation the defendants now claim they need to undertake. For example, the Government produced MCC video surveillance for a period of longer than one month (July 5, 2019 to August 12, 2019); count slips for nearly three weeks (July 23, 2019 to August 14, 2019); thirty-minute round reports for more than a month (July 1, 2019 to August 10, 2019); and materials relating to the events of July 23, 2019. Similarly, with respect to defendant Noel, the Government provided in discovery to her only a report from her cellphone, which consists of more than 20,000 pages, very few of which, if any, are relevant to the pending charges.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "For substantially the same reasons, and as the Court is aware, the",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "1 For the third production, the Government requested additional hard drives from defense counsel. To date, only Noel's counsel provided a hard drive to the Government, which the Government then loaded and returned to counsel. The Government stands ready to do the same for Thomas as soon as a hard drive is provided.",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00021998",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Analisa Torres",
      "Noel",
      "Thomas"
    ],
    "organizations": [
      "U.S. Department of Justice",
      "United States Attorney",
      "Southern District of New York"
    ],
    "locations": [
      "New York",
      "Silvio J. Mollo Building",
      "One Saint Andrew's Plaza",
      "500 Pearl Street"
    ],
    "dates": [
      "January 28, 2020",
      "January 27, 2020",
      "April 20, 2020",
      "August 9, 2019",
      "August 10, 2019",
      "December 31, 2019",
      "January 23, 2020",
      "January 24, 2020",
      "July 5, 2019",
      "August 12, 2019",
      "July 23, 2019",
      "August 14, 2019",
      "July 1, 2019"
    ],
    "reference_numbers": [
      "1:19-cr-00830-AT",
      "19 Cr. 830 (AT)",
      "DOJ-OGR-00021998"
    ]
  },
  "additional_notes": "The document is a court filing from the U.S. Department of Justice, United States Attorney for the Southern District of New York. It is a letter to Judge Analisa Torres regarding the case United States v. Noel and Thomas, 19 Cr. 830 (AT). The document is typed and contains no handwritten text or stamps."
}