mirror-epstein-docs/results/IMAGES002/DOJ-OGR-00003861.json

{
  "document_metadata": {
    "page_number": "1 of 2",
    "document_number": "219",
    "date": "04/19/21",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": true
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 219 Filed 04/19/21 Page 1 of 2\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\nApril 19, 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 writes with respect to the Court's Order dated April 19, 2021, which directed the Government to notify the Court by tomorrow whether it intends to \"use any of the documents subject to the pending motions to suppress in the trial of the non-perjury counts in this case.\" (Dkt. No. 216). The Government respectfully requests that the Court grant the Government until Thursday, April 22, 2021, to submit its response.\nThe Government is carefully considering the Court's Order, and has begun reviewing its file, considering legal issues, and having internal conversations with supervisors in order to thoughtfully and accurately respond to the Court. In particular, although the materials at issue are not likely to be central to the Government's case in chief in the trial of the non-perjury counts, the Government nonetheless recognizes the importance of anticipating how these materials may be relevant to (and used at) the trial. For example, and among other considerations, the materials include transcripts of depositions of witnesses who may testify at trial, and the Government is mindful of potential uses of such material that might arise during the cross-examination of both Government and defense witnesses whose prior statements are encompassed within the materials at issue.\nDOJ-OGR-00003861",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 219 Filed 04/19/21 Page 1 of 2",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "U.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\nApril 19, 2021",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "BY 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",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)\nDear Judge Nathan:",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The Government writes with respect to the Court's Order dated April 19, 2021, which directed the Government to notify the Court by tomorrow whether it intends to \"use any of the documents subject to the pending motions to suppress in the trial of the non-perjury counts in this case.\" (Dkt. No. 216). The Government respectfully requests that the Court grant the Government until Thursday, April 22, 2021, to submit its response.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The Government is carefully considering the Court's Order, and has begun reviewing its file, considering legal issues, and having internal conversations with supervisors in order to thoughtfully and accurately respond to the Court. In particular, although the materials at issue are not likely to be central to the Government's case in chief in the trial of the non-perjury counts, the Government nonetheless recognizes the importance of anticipating how these materials may be relevant to (and used at) the trial. For example, and among other considerations, the materials include transcripts of depositions of witnesses who may testify at trial, and the Government is mindful of potential uses of such material that might arise during the cross-examination of both Government and defense witnesses whose prior statements are encompassed within the materials at issue.",
      "position": "middle"
    },
    {
      "type": "stamp",
      "content": "DOJ-OGR-00003861",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ghislaine Maxwell"
    ],
    "organizations": [
      "U.S. Department of Justice",
      "United States Attorney",
      "United States District Court"
    ],
    "locations": [
      "New York",
      "Southern District of New York"
    ],
    "dates": [
      "April 19, 2021",
      "April 22, 2021"
    ],
    "reference_numbers": [
      "20 Cr. 330 (AJN)",
      "Dkt. No. 216",
      "Case 1:20-cr-00330-PAE",
      "Document 219"
    ]
  },
  "additional_notes": "The document appears to be a formal letter from the U.S. Department of Justice to the Honorable Alison J. Nathan, regarding the case United States v. Ghislaine Maxwell. The document is typed and contains a stamp at the bottom."
}