mirror-epstein-docs/results/IMAGES003/DOJ-OGR-00006162.json

{
  "document_metadata": {
    "page_number": "1",
    "document_number": "411",
    "date": "11/04/21",
    "document_type": "Court Document",
    "has_handwriting": false,
    "has_stamps": true
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 411 Filed 11/04/21 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\nNovember 4, 2021\nBY ECF\nThe Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\nUnited States Courthouse\n40 Foley Square\nNew York, New York 10007\nRe: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)\nDear Judge Nathan:\nThe Government respectfully moves for reconsideration of the portions of the Court's order dated November 3, 2021 (Dkt. No. 409), directing the Government to file by November 8, 2021, any briefing to exclude any defense witness testimony disclosed on November 1, 2021, with defense responses due November 11, 2021.\nThis schedule provides the Government seven days—or six, if timed from the Court's order—to respond to the defense's expert notice, in which they gave notice for the first time of eight potential experts. By contrast, the Government notes that it provided the defense with notice of its expert on April 23, 2021, and the defense filed its motion to preclude on October 18, 2021.1\nMoreover, during that time, the Government will be (1) preparing for the November 10, 2021 Daubert hearing; (2) responding to the defendant's motion for reconsideration regarding disclosure of juror names (Dkt. No. 407); (3) providing the defense with categories of its co-conspirator statements and exemplars; (4) briefing the admissibility of Minor Victim-3's testimony admission through Rule 702 on September 15, 2021. The defense has not moved to preclude that witness.\n1 The Government also provided expert notice of a witness who it does not believe requires admission through Rule 702 on September 15, 2021. The defense has not moved to preclude that witness.\nDOJ-OGR-00006162",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 411 Filed 11/04/21 Page 1 of 3",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "U.S Department of Justice\nUnited States Attorney\nSouthern District of New York",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "The Silvio J. Mollo Building\nOne Saint Andrew's Plaza\nNew York, New York 10007",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "November 4, 2021",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "BY ECF",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\nUnited States Courthouse\n40 Foley Square\nNew York, New York 10007",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Dear Judge Nathan:",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The Government respectfully moves for reconsideration of the portions of the Court's order dated November 3, 2021 (Dkt. No. 409), directing the Government to file by November 8, 2021, any briefing to exclude any defense witness testimony disclosed on November 1, 2021, with defense responses due November 11, 2021.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "This schedule provides the Government seven days—or six, if timed from the Court's order—to respond to the defense's expert notice, in which they gave notice for the first time of eight potential experts. By contrast, the Government notes that it provided the defense with notice of its expert on April 23, 2021, and the defense filed its motion to preclude on October 18, 2021.1",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Moreover, during that time, the Government will be (1) preparing for the November 10, 2021 Daubert hearing; (2) responding to the defendant's motion for reconsideration regarding disclosure of juror names (Dkt. No. 407); (3) providing the defense with categories of its co-conspirator statements and exemplars; (4) briefing the admissibility of Minor Victim-3's testimony admission through Rule 702 on September 15, 2021. The defense has not moved to preclude that witness.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "1 The Government also provided expert notice of a witness who it does not believe requires admission through Rule 702 on September 15, 2021. The defense has not moved to preclude that witness.",
      "position": "footer"
    },
    {
      "type": "stamp",
      "content": "DOJ-OGR-00006162",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ghislaine Maxwell",
      "Minor Victim-3"
    ],
    "organizations": [
      "U.S Department of Justice",
      "United States Attorney",
      "United States District Court"
    ],
    "locations": [
      "New York"
    ],
    "dates": [
      "November 4, 2021",
      "November 3, 2021",
      "November 8, 2021",
      "November 1, 2021",
      "November 11, 2021",
      "April 23, 2021",
      "October 18, 2021",
      "November 10, 2021",
      "September 15, 2021"
    ],
    "reference_numbers": [
      "20 Cr. 330 (AJN)",
      "Dkt. No. 409",
      "Dkt. No. 407",
      "DOJ-OGR-00006162"
    ]
  },
  "additional_notes": "The document appears to be a court filing in the case United States v. Ghislaine Maxwell. The document is a motion for reconsideration filed by the Government. The document is typed and contains a stamp with a reference number."
}