mirror-epstein-docs/results/IMAGES002/DOJ-OGR-00004117.json

{
  "document_metadata": {
    "page_number": "1",
    "document_number": "276",
    "date": "05/11/21",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 276 Filed 05/11/21 Page 1 of 4\nLAW OFFICES OF BOBBI C. STERNHEIM\n212-243-1100 * Main\n917-306-6666 * Cell\n888-587-4737 * Fax\n33 West 19th Street - 4th Floor\nNew York, New York 10011\nbc@sternheimlaw.com\nMay 10, 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:\nWe write in response to the government's May 10, 2021 letter to the Court regarding the trial start date. This Court ordered that the parties meet and confer regarding a trial start date and to \"agree to the earliest possible trial date this fall and to seek adjustments to other schedules in order to facilitate an early fall trial start date.\" (Dkt. 266 at 3). Defense counsel attempted to confer with the government in good faith to find a mutually acceptable date. We sent several emails to counsel stating our reliance on our April 22d submission (Dkt. 246) where we specified our conflicts and the justification for our request. By contrast, and despite our requests for clarification, the government failed to provide any details to justify its request to delay the trial start to November 29, 2021. Instead, the government filed a lengthy submission to the Court, complete with case law citations, at 8:12 p.m., a few hours before the deadline for the \"joint letter.\" Moreover, the government also audaciously seeks by way of their joint letter regarding the trial date to re-litigate the schedule this Court has already crafted after hearing from the parties both on submissions and in person, without even the courtesy of a motion for reconsideration on that schedule.\nFor the reasons previously detailed in our April 22d letter to the Court, defense counsel's earliest possible - and preferred - trial start date is November 8th. As the Court is aware, Judge Furman moved my October 4th trial to March, clearing the way for this trial to start on November\nDOJ-OGR-00004117",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 276 Filed 05/11/21 Page 1 of 4",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "LAW OFFICES OF BOBBI C. STERNHEIM",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "212-243-1100 * Main\n917-306-6666 * Cell\n888-587-4737 * Fax\n33 West 19th Street - 4th Floor\nNew York, New York 10011\nbc@sternheimlaw.com",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "May 10, 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": "We write in response to the government's May 10, 2021 letter to the Court regarding the trial start date. This Court ordered that the parties meet and confer regarding a trial start date and to \"agree to the earliest possible trial date this fall and to seek adjustments to other schedules in order to facilitate an early fall trial start date.\" (Dkt. 266 at 3). Defense counsel attempted to confer with the government in good faith to find a mutually acceptable date. We sent several emails to counsel stating our reliance on our April 22d submission (Dkt. 246) where we specified our conflicts and the justification for our request. By contrast, and despite our requests for clarification, the government failed to provide any details to justify its request to delay the trial start to November 29, 2021. Instead, the government filed a lengthy submission to the Court, complete with case law citations, at 8:12 p.m., a few hours before the deadline for the \"joint letter.\" Moreover, the government also audaciously seeks by way of their joint letter regarding the trial date to re-litigate the schedule this Court has already crafted after hearing from the parties both on submissions and in person, without even the courtesy of a motion for reconsideration on that schedule.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "For the reasons previously detailed in our April 22d letter to the Court, defense counsel's earliest possible - and preferred - trial start date is November 8th. As the Court is aware, Judge Furman moved my October 4th trial to March, clearing the way for this trial to start on November",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00004117",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ghislaine Maxwell",
      "Bobbi C. Sternheim",
      "Furman"
    ],
    "organizations": [
      "Law Offices of Bobbi C. Sternheim",
      "United States Courthouse"
    ],
    "locations": [
      "New York"
    ],
    "dates": [
      "May 10, 2021",
      "April 22",
      "November 29, 2021",
      "November 8",
      "October 4",
      "March",
      "May 11, 2021"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "276",
      "S2 20 Cr. 330 (AJN)",
      "Dkt. 266",
      "Dkt. 246",
      "DOJ-OGR-00004117"
    ]
  },
  "additional_notes": "The document appears to be a formal letter from the Law Offices of Bobbi C. Sternheim to Judge Alison J. Nathan regarding the trial start date for the case United States v. Ghislaine Maxwell. The letter is typed and contains legal terminology and references to court documents."
}