mirror-epstein-docs/results/IMAGES003/DOJ-OGR-00008862.json

{
  "document_metadata": {
    "page_number": "1",
    "document_number": "55921",
    "date": "February 1, 2022",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": true
  },
  "full_text": "Case#: 2020cr00308 (AJN) Document#: 55921 Filed:02/02/2022 Page#: 1 of 1 COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 +1 212 957 7600 phone www.cohengresser.com Christian R. Everdell +1 (212) 957-7600 ceverdell@cohengresser.com USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC #: DATE FILED: 2/2/22 BY ECF February 1, 2022 The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, NY 10007 Re: United States v. Ghislaine Maxwell, S2 20 Cr. 330 (AJN) Dear Judge Nathan: We write on behalf of our client, Ghislaine Maxwell, to respectfully request a one-week extension of time until Friday, February 11, 2022 to file our post-trial motions. The motions are currently due on Friday, February 4, 2022. We have conferred with the government, which has consented to the requested extension. The requested extension is necessary because we need to meet with Ms. Maxwell in person to review work product related to the motions. In-person visits at the MDC only recently became available again this week. Due to other commitments, we are unable to meet with Ms. Maxwell until the end of this week. This is the defense's first request for an extension. We would consent to a similar one-week extension for the government to file its response. Sincerely, /s/ Christian Everdell Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue, 21st Floor New York, New York 10022 (212) 957-7600 cc: All Counsel of Record (By ECF) 2087993.1 The extension request is hereby GRANTED. The briefing schedule for other post-verdict motions is revised as follows: - Defense submission: February 11, 2022 - Government response: February 25, 2022 - Defense reply: March 11, 2022 SO ORDERED. Alison J. Nathan 2/2/22 DOJ-OGR-00008862",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case#: 2020cr00308 (AJN) Document#: 55921 Filed:02/02/2022 Page#: 1 of 1",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 +1 212 957 7600 phone www.cohengresser.com",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Christian R. Everdell +1 (212) 957-7600 ceverdell@cohengresser.com",
      "position": "header"
    },
    {
      "type": "stamp",
      "content": "USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC #: DATE FILED: 2/2/22",
      "position": "margin"
    },
    {
      "type": "printed",
      "content": "February 1, 2022 The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, NY 10007",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Re: United States v. Ghislaine Maxwell, S2 20 Cr. 330 (AJN)",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Dear Judge Nathan: We write on behalf of our client, Ghislaine Maxwell, to respectfully request a one-week extension of time until Friday, February 11, 2022 to file our post-trial motions. The motions are currently due on Friday, February 4, 2022. We have conferred with the government, which has consented to the requested extension. The requested extension is necessary because we need to meet with Ms. Maxwell in person to review work product related to the motions. In-person visits at the MDC only recently became available again this week. Due to other commitments, we are unable to meet with Ms. Maxwell until the end of this week. This is the defense's first request for an extension. We would consent to a similar one-week extension for the government to file its response.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Sincerely, /s/ Christian Everdell Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue, 21st Floor New York, New York 10022 (212) 957-7600",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "cc: All Counsel of Record (By ECF) 2087993.1",
      "position": "footer"
    },
    {
      "type": "handwritten",
      "content": "Alison J. Nathan 2/2/22",
      "position": "margin"
    },
    {
      "type": "printed",
      "content": "The extension request is hereby GRANTED. The briefing schedule for other post-verdict motions is revised as follows: - Defense submission: February 11, 2022 - Government response: February 25, 2022 - Defense reply: March 11, 2022 SO ORDERED.",
      "position": "margin"
    }
  ],
  "entities": {
    "people": [
      "Christian R. Everdell",
      "Alison J. Nathan",
      "Ghislaine Maxwell"
    ],
    "organizations": [
      "COHEN & GRESSER LLP",
      "United States District Court",
      "United States Courthouse"
    ],
    "locations": [
      "New York",
      "Southern District of New York",
      "MDC"
    ],
    "dates": [
      "February 1, 2022",
      "February 4, 2022",
      "February 11, 2022",
      "February 25, 2022",
      "March 11, 2022"
    ],
    "reference_numbers": [
      "2020cr00308",
      "55921",
      "S2 20 Cr. 330 (AJN)",
      "2087993.1",
      "DOJ-OGR-00008862"
    ]
  },
  "additional_notes": "The document is a letter requesting an extension of time to file post-trial motions in the case of United States v. Ghislaine Maxwell. The letter is signed by Christian R. Everdell and includes a stamp indicating that it was electronically filed with the USDC SDNY on February 2, 2022. The document also includes a handwritten signature of Judge Alison J. Nathan and a notation that the extension request is granted."
}