{
  "document_metadata": {
    "page_number": "2",
    "document_number": "2256",
    "date": "4/29/21",
    "document_type": "Letter",
    "has_handwriting": true,
    "has_stamps": false
  },
  "full_text": "Case#: 2020-cr-0000389-AEN Document#: 2256 Filed#: 04/29/2021 Page#: 2 of 2 LAW OFFICES OF BOBBI C. STERNHEIM The MDC routinely places inmates in the SHU if they have engaged in physical altercation with other inmates or to protect inmates who are the subject of abuse. It would be ironic if the MDC follows through with its threat to place Ms. Maxwell in the SHU: It would signal that Ms. Maxwell needs protection from the very staff so intent on protecting her, since she has no contact with anyone but staff. As suggested by the Circuit, we ask the Court to address Ms. Maxwell's sleeping conditions by directing the MDC to cease 15-minute light surveillance of Ms. Maxwell or justify the need for the disruptive flashlight surveillance. Very truly yours, Bobbi C. Sternheim BOBBI C. STERNHEIM Encs. cc: All counsel of record By May 5, 2021, the Government is ORDERED to confer with MDC legal counsel and provide the Court responses to the following questions: 1. Is Ms. Maxwell being subjected to flashlight surveillance every 15 minutes at night? Or any other atypical flashlight surveillance? 2. If so, what is the basis for doing so? 3. And if so, can she be provided with appropriate eye covering? The Government is further ORDERED to share its response with defense counsel before filing it on ECF so that defense counsel can indicate whether they believe any private medical information needs to be redacted before public filing. SO ORDERED. ALISON J. NATHAN, U.S.D.J. 4/29/21 2 DOJ-OGR-00004059",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case#: 2020-cr-0000389-AEN Document#: 2256 Filed#: 04/29/2021 Page#: 2 of 2",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "LAW OFFICES OF BOBBI C. STERNHEIM",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "The MDC routinely places inmates in the SHU if they have engaged in physical altercation with other inmates or to protect inmates who are the subject of abuse. It would be ironic if the MDC follows through with its threat to place Ms. Maxwell in the SHU: It would signal that Ms. Maxwell needs protection from the very staff so intent on protecting her, since she has no contact with anyone but staff.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "As suggested by the Circuit, we ask the Court to address Ms. Maxwell's sleeping conditions by directing the MDC to cease 15-minute light surveillance of Ms. Maxwell or justify the need for the disruptive flashlight surveillance.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Very truly yours,",
      "position": "middle"
    },
    {
      "type": "handwritten",
      "content": "Bobbi C. Sternheim",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "BOBBI C. STERNHEIM",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Encs. cc: All counsel of record",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "By May 5, 2021, the Government is ORDERED to confer with MDC legal counsel and provide the Court responses to the following questions: 1. Is Ms. Maxwell being subjected to flashlight surveillance every 15 minutes at night? Or any other atypical flashlight surveillance? 2. If so, what is the basis for doing so? 3. And if so, can she be provided with appropriate eye covering?",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "The Government is further ORDERED to share its response with defense counsel before filing it on ECF so that defense counsel can indicate whether they believe any private medical information needs to be redacted before public filing.",
      "position": "bottom"
    },
    {
      "type": "handwritten",
      "content": "Alison J. Nathan",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "SO ORDERED. ALISON J. NATHAN, U.S.D.J.",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "2",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00004059",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Bobbi C. Sternheim",
      "Alison J. Nathan",
      "Ms. Maxwell"
    ],
    "organizations": [
      "MDC",
      "Circuit Court"
    ],
    "locations": [],
    "dates": [
      "May 5, 2021",
      "4/29/21"
    ],
    "reference_numbers": [
      "2020-cr-0000389-AEN",
      "2256",
      "DOJ-OGR-00004059"
    ]
  },
  "additional_notes": "The document appears to be a court filing with a letter from Bobbi C. Sternheim to the court and a court order signed by Alison J. Nathan. The document is well-formatted and legible."
}