mirror-epstein-docs/results/IMAGES002/DOJ-OGR-00003952.json

{
  "document_metadata": {
    "page_number": "10",
    "document_number": "235",
    "date": "04/22/21",
    "document_type": "court document",
    "has_handwriting": true,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 235 Filed 04/22/21 Page 10 of 10\nPage 10\n\nas scheduled, and has already planned to be available to testify at trial as scheduled this summer, despite her personal and professional obligations. These views further weigh against an adjournment of the July 12, 2021 trial date.\n\nFinally, although the Government maintains that an adjournment is not warranted here, if the Court nevertheless adjourns trial, the Government respectfully requests that the new trial date be scheduled for March 2022. Were the trial to be scheduled for any date between September 2021 and February 2022, one or more of the undersigned prosecutors, including prosecutors who have been on this case for multiple years, would be unable to participate in the trial given pre-existing trial commitments,5 among other reasons. Given the complexities in this case, including a large volume of discovery, litigation history involving numerous legal and factual issues, years of investigation, and relationships with the victims, continuity of Government counsel at trial is a particularly compelling interest here. Accordingly, the Government respectfully requests that, should an adjournment be granted, any new trial date be set for March 2022.\n\nRespectfully submitted,\nAUDREY STRAUSS\nUnited States Attorney\n\nBy: Maurene Comey / Alison Moe\nLara Pomerantz / Andrew Rohrbach\nAssistant United States Attorneys\nSouthern District of New York\n212-637-2324\n\nCc: All Counsel of Record (By ECF)\n\n5 In particular, AUSA Pomerantz has a trial scheduled to begin on October 4, 2021, which is expected to last approximately eight weeks, and a trial scheduled to begin on January 5, 2022, which is expected to last approximately six weeks. Additionally, AUSA Moe has a trial scheduled to take place in the fourth quarter of 2021, pursuant to this District's COVID-19 scheduling protocols, which is expected to last at least two weeks.\n\nDOJ-OGR-00003952",
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      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 235 Filed 04/22/21 Page 10 of 10",
      "position": "header"
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    {
      "type": "printed",
      "content": "Page 10",
      "position": "header"
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    {
      "type": "printed",
      "content": "as scheduled, and has already planned to be available to testify at trial as scheduled this summer, despite her personal and professional obligations. These views further weigh against an adjournment of the July 12, 2021 trial date.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Finally, although the Government maintains that an adjournment is not warranted here, if the Court nevertheless adjourns trial, the Government respectfully requests that the new trial date be scheduled for March 2022. Were the trial to be scheduled for any date between September 2021 and February 2022, one or more of the undersigned prosecutors, including prosecutors who have been on this case for multiple years, would be unable to participate in the trial given pre-existing trial commitments,5 among other reasons. Given the complexities in this case, including a large volume of discovery, litigation history involving numerous legal and factual issues, years of investigation, and relationships with the victims, continuity of Government counsel at trial is a particularly compelling interest here. Accordingly, the Government respectfully requests that, should an adjournment be granted, any new trial date be set for March 2022.",
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    {
      "type": "printed",
      "content": "Respectfully submitted,",
      "position": "body"
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    {
      "type": "printed",
      "content": "AUDREY STRAUSS",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "United States Attorney",
      "position": "body"
    },
    {
      "type": "handwritten",
      "content": "By: Maurene Comey / Alison Moe Lara Pomerantz / Andrew Rohrbach",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Assistant United States Attorneys Southern District of New York 212-637-2324",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Cc: All Counsel of Record (By ECF)",
      "position": "footer"
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    {
      "type": "printed",
      "content": "5 In particular, AUSA Pomerantz has a trial scheduled to begin on October 4, 2021, which is expected to last approximately eight weeks, and a trial scheduled to begin on January 5, 2022, which is expected to last approximately six weeks. Additionally, AUSA Moe has a trial scheduled to take place in the fourth quarter of 2021, pursuant to this District's COVID-19 scheduling protocols, which is expected to last at least two weeks.",
      "position": "footer"
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    {
      "type": "printed",
      "content": "DOJ-OGR-00003952",
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  ],
  "entities": {
    "people": [
      "Audrey Strauss",
      "Maurene Comey",
      "Alison Moe",
      "Lara Pomerantz",
      "Andrew Rohrbach",
      "AUSA Pomerantz",
      "AUSA Moe"
    ],
    "organizations": [
      "United States Attorney",
      "Southern District of New York"
    ],
    "locations": [
      "New York"
    ],
    "dates": [
      "July 12, 2021",
      "March 2022",
      "September 2021",
      "February 2022",
      "October 4, 2021",
      "January 5, 2022",
      "04/22/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "235",
      "DOJ-OGR-00003952"
    ]
  },
  "additional_notes": "The document appears to be a court filing with a clear and legible format. There are no visible redactions or damage to the document."
}