{
  "document_metadata": {
    "page_number": "2 of 3",
    "document_number": "346",
    "date": "10/14/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 346 Filed 10/14/21 Page 2 of 3 LAW OFFICES OF BOBBI C. STERNHEIM counsel. They compromise her right to prepare her defense and deprive her of her constitutional right to effective assistance of counsel. Ms. Maxwell has been in custody for over 15 months without access to the evidence the Government intends to introduce at trial. The Court established a deadline of October 11 for those and other materials to be disclosed. Late in the evening of October 11, the Government produced to counsel approximately 14,0001 pages of single-spaced witness materials, as well as numerous exhibits and its purported 404(b) Notice and Co-Conspirator Notice. But the Government refused to hand-deliver those materials to MDC as they have with previous productions in this case. Because the MDC will not accept hard drives from defense counsel but will from the Government, counsel provided hard-drives to the Government a week in advance of October 11 and requested that it hand deliver the hard drive to MDC on October 11, the day of Court-ordered disclosure. The government denied this request, choosing instead to send the hard drive via FedEx. Tracking information confirms that the MDC received the hard drive on October 12. On October 13, counsel informed the Government that Ms. Maxwell still had not received the hard drive and emailed MDC Legal. Again this morning, counsel emailed MDC Legal regarding the failure to provide Ms. Maxwell with the hard drive containing 3500 material. The MDC has failed to respond. Ms. Maxwell did not receive the hard drive until late this morning. It is imperative that the Court intervene. As we approach trial, it is ever more imperative that critical trial documents and Jencks Act and Giglio material be given to Ms. Maxwell promptly upon delivery to the institution. Based on the MDC's inefficiency and mishandling of legal mail, I have no confidence MDC is capable of fulfilling its responsibilities and every reason 1 There appear to be approximately 8,000 pages of testifying witness materials, and another 6,000 single-spaced pages of newly produced \"non-testifying witness\" materials, the bulk of which appears exculpatory. 2 DOJ-OGR-00005230",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 346 Filed 10/14/21 Page 2 of 3",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "LAW OFFICES OF BOBBI C. STERNHEIM",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "counsel. They compromise her right to prepare her defense and deprive her of her constitutional right to effective assistance of counsel. Ms. Maxwell has been in custody for over 15 months without access to the evidence the Government intends to introduce at trial. The Court established a deadline of October 11 for those and other materials to be disclosed. Late in the evening of October 11, the Government produced to counsel approximately 14,0001 pages of single-spaced witness materials, as well as numerous exhibits and its purported 404(b) Notice and Co-Conspirator Notice. But the Government refused to hand-deliver those materials to MDC as they have with previous productions in this case. Because the MDC will not accept hard drives from defense counsel but will from the Government, counsel provided hard-drives to the Government a week in advance of October 11 and requested that it hand deliver the hard drive to MDC on October 11, the day of Court-ordered disclosure. The government denied this request, choosing instead to send the hard drive via FedEx. Tracking information confirms that the MDC received the hard drive on October 12. On October 13, counsel informed the Government that Ms. Maxwell still had not received the hard drive and emailed MDC Legal. Again this morning, counsel emailed MDC Legal regarding the failure to provide Ms. Maxwell with the hard drive containing 3500 material. The MDC has failed to respond. Ms. Maxwell did not receive the hard drive until late this morning. It is imperative that the Court intervene. As we approach trial, it is ever more imperative that critical trial documents and Jencks Act and Giglio material be given to Ms. Maxwell promptly upon delivery to the institution. Based on the MDC's inefficiency and mishandling of legal mail, I have no confidence MDC is capable of fulfilling its responsibilities and every reason",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "1 There appear to be approximately 8,000 pages of testifying witness materials, and another 6,000 single-spaced pages of newly produced \"non-testifying witness\" materials, the bulk of which appears exculpatory.",
      "position": "footnote"
    },
    {
      "type": "printed",
      "content": "2",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00005230",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Ms. Maxwell",
      "Bobbi C. Sternheim"
    ],
    "organizations": [
      "Government",
      "MDC",
      "MDC Legal",
      "LAW OFFICES OF BOBBI C. STERNHEIM",
      "DOJ"
    ],
    "locations": [],
    "dates": [
      "October 11",
      "October 12",
      "October 13",
      "10/14/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 346",
      "DOJ-OGR-00005230"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Ms. Maxwell, discussing issues with the delivery of evidence and materials to her while in custody. The document is typed and contains a footnote with additional information. There are no visible stamps or handwritten text."
}