mirror-epstein-docs/results/IMAGES001/DOJ-OGR-00001389.json

{
  "document_metadata": {
    "page_number": "3",
    "document_number": "20-cr-00330",
    "date": "April 15, 2021",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330 Document 118 Filed 04/15/21 Page 3 of 8\nLAW OFFICES OF BOBBI C. STERNHEIM\n212-243-1100 · Main\n917-306-6666 · Cell\n888-587-4737 · Fax\n33 West 19th Street - 4th Floor\nNew York, New York 10011\nbc@sternheimlaw.com\nApril 15, 2021\nHonorable Alison J. Nathan\nUnited States District Judge\nUnited States Courthouse\n40 Foley Square\nNew York, NY 10007\nRe: United States v. Ghislaine Maxwell\nS2 20 Cr. 330 (AJN)\nDear Judge Nathan:\nWe write in reply to the government's April 9th letter opposing a trial continuance.\nThe defense has been steadfastly and diligently preparing for a July 12th trial based on the original indictment, a date set on the condition that there would be no superseding indictment adding substantive charges. The recently filed superseding indictment directly contravenes that agreement and adds two new charges which vastly expand the relevant time period from a four-year period in the 1990s to an eleven-year period stretching from 1994 to 2004. These additions significantly alter the scope of the government's case and necessarily shift the focus of the defense's trial preparation. Instead of being focused on mounting a defense to the allegations of the three accusers from the 1990s, as we have been doing, the defense will now have to spend considerable time and resources investigating allegations of new conduct in a completely different time period involving numerous additional witnesses, and with all of the difficulties that COVID restrictions still place on a meaningful defense investigation.\nWe do not want to postpone the trial but have no choice but to ask for a continuance. The government bears responsibility for this need, having filed a late-breaking superseding indictment based on a witness who has been known to the government since the Florida\nDOJ-OGR-00001389",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330 Document 118 Filed 04/15/21 Page 3 of 8",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "LAW OFFICES OF BOBBI C. STERNHEIM",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "212-243-1100 · Main\n917-306-6666 · Cell\n888-587-4737 · Fax",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "33 West 19th Street - 4th Floor\nNew York, New York 10011\nbc@sternheimlaw.com",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "April 15, 2021",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Honorable Alison J. Nathan\nUnited States District Judge\nUnited States Courthouse\n40 Foley Square\nNew York, NY 10007",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Re: United States v. Ghislaine Maxwell\nS2 20 Cr. 330 (AJN)",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Dear Judge Nathan:",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "We write in reply to the government's April 9th letter opposing a trial continuance.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The defense has been steadfastly and diligently preparing for a July 12th trial based on the original indictment, a date set on the condition that there would be no superseding indictment adding substantive charges. The recently filed superseding indictment directly contravenes that agreement and adds two new charges which vastly expand the relevant time period from a four-year period in the 1990s to an eleven-year period stretching from 1994 to 2004. These additions significantly alter the scope of the government's case and necessarily shift the focus of the defense's trial preparation. Instead of being focused on mounting a defense to the allegations of the three accusers from the 1990s, as we have been doing, the defense will now have to spend considerable time and resources investigating allegations of new conduct in a completely different time period involving numerous additional witnesses, and with all of the difficulties that COVID restrictions still place on a meaningful defense investigation.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "We do not want to postpone the trial but have no choice but to ask for a continuance. The government bears responsibility for this need, having filed a late-breaking superseding indictment based on a witness who has been known to the government since the Florida",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00001389",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ghislaine Maxwell",
      "Bobbi C. Sternheim"
    ],
    "organizations": [
      "Law Offices of Bobbi C. Sternheim",
      "United States Courthouse"
    ],
    "locations": [
      "New York",
      "Florida"
    ],
    "dates": [
      "April 15, 2021",
      "April 9th",
      "July 12th",
      "1994",
      "2004"
    ],
    "reference_numbers": [
      "20-cr-00330",
      "S2 20 Cr. 330 (AJN)",
      "DOJ-OGR-00001389"
    ]
  },
  "additional_notes": "The document appears to be a formal letter from the Law Offices of Bobbi C. Sternheim to Honorable Alison J. Nathan regarding the case United States v. Ghislaine Maxwell. The letter is typed and contains no handwritten text or stamps. The document is in good condition with no visible damage or redactions."
}