mirror-epstein-docs/results/IMAGES002/DOJ-OGR-00005385.json

{
  "document_metadata": {
    "page_number": "1",
    "document_number": "375",
    "date": "October 27, 2021",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 375 Filed 10/27/21 Page 1 of 2\nLAW OFFICES OF BOBBI C. STERNHEIM\n212-243-1100 – Main\n917-912-9698 – Cell\n888-587-4737 – Fax\n225 Broadway, Suite 715\nNew York, NY 10007\nbcsternheim@mac.com\nOctober 27, 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:\nIn response to the Court’s Order dated October 22, 2021, regarding the Court’s draft preliminary remarks for prospective jurors (Dkt. 366), the government took the opportunity to reargue its request that counsel exercise challenges to the final venire on the last day of jury section (November 19) rather than on November 29. The Court merely invited a discrete response to its proposed address to prospective jury but the government seized the opportunity to reargue.\nDuring the October 21 conference, the defense stated its reasons for preferring November 29, a date when the Court could inquire whether any prospective jury might not be able to be fair or otherwise impacted or influenced by any reference to this case during the 10-day interval that included the Thanksgiving holiday. Further, it would eliminate the need to substitute alternates in the event any juror was exposed to COVID or otherwise became ill. If last year was any indication, Thanksgiving week is a likely time for COVID to spike due to high-volume travel, students returning home from college, and friends and families congregating. Even an exposure to the virus during the holidays can necessitate a prospective juror to quarantine for a time period past November 29.\nDuring the conference, the government pressed for November 19 because it wanted a have a firm start date for witnesses coming from out of state. November 29 is the firm start date and openings will commence following exercise of challenges and the swearing in of the jury. The government appears\nDOJ-OGR-00005385",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 375 Filed 10/27/21 Page 1 of 2",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "LAW OFFICES OF BOBBI C. STERNHEIM",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "212-243-1100 – Main\n917-912-9698 – Cell\n888-587-4737 – Fax\n225 Broadway, Suite 715\nNew York, NY 10007\nbcsternheim@mac.com",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "October 27, 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": "top"
    },
    {
      "type": "printed",
      "content": "In response to the Court’s Order dated October 22, 2021, regarding the Court’s draft preliminary remarks for prospective jurors (Dkt. 366), the government took the opportunity to reargue its request that counsel exercise challenges to the final venire on the last day of jury section (November 19) rather than on November 29. The Court merely invited a discrete response to its proposed address to prospective jury but the government seized the opportunity to reargue.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "During the October 21 conference, the defense stated its reasons for preferring November 29, a date when the Court could inquire whether any prospective jury might not be able to be fair or otherwise impacted or influenced by any reference to this case during the 10-day interval that included the Thanksgiving holiday. Further, it would eliminate the need to substitute alternates in the event any juror was exposed to COVID or otherwise became ill. If last year was any indication, Thanksgiving week is a likely time for COVID to spike due to high-volume travel, students returning home from college, and friends and families congregating. Even an exposure to the virus during the holidays can necessitate a prospective juror to quarantine for a time period past November 29.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "During the conference, the government pressed for November 19 because it wanted a have a firm start date for witnesses coming from out of state. November 29 is the firm start date and openings will commence following exercise of challenges and the swearing in of the jury. The government appears",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00005385",
      "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",
      "United States"
    ],
    "dates": [
      "October 27, 2021",
      "October 22, 2021",
      "November 19",
      "November 29",
      "October 21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 375",
      "S2 20 Cr. 330 (AJN)",
      "Dkt. 366",
      "DOJ-OGR-00005385"
    ]
  },
  "additional_notes": "The document appears to be a formal letter from Bobbi C. Sternheim to Judge Alison J. Nathan regarding the case United States v. Ghislaine Maxwell. The letter discusses the government's request to exercise challenges to the final venire on November 19 rather than November 29. The document is well-formatted and free of significant damage or redactions."
}