{
  "document_metadata": {
    "page_number": "5",
    "document_number": "42",
    "date": "August 17, 2020",
    "document_type": "Court Document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 42 Filed 08/17/20 Page 5 of 5\n\nThe Honorable Alison J. Nathan\nAugust 17, 2020\nPage 5\n\nunder constant observation by multiple prison guards.3 She is also still being awakened several times in the middle of the night. Even on more routine matters, Ms. Maxwell's treatment has been worse than other pretrial detainees. For example, Ms. Maxwell has no access to email and has been given 30 minutes per month for personal phone calls, far fewer than the 500 minutes granted to other pretrial detainees since the COVID-19 crisis. Unlike defendants in the general population, she does not have a desk or a writing surface where she can take notes when reviewing the discovery. And until recently, Ms. Maxwell was denied access to the prison commissary for no apparent reason.\n\nWe respect that the BOP needs to ensure the orderly operation of the MDC. But Ms. Maxwell's conditions of confinement are unique to her and seem punitive rather than anything necessary to ensure that the MDC as a whole is running smoothly. Accordingly, we respectfully request that, going forward, Ms. Maxwell be monitored in the same manner as other pretrial detainees and that the Court order the BOP to grant Ms. Maxwell the same privileges given to other detainees.4\n\n*   *   *\n\nFor the reasons set forth above, we respectfully submit that the Court should grant Ms. Maxwell's motion.\n\nRespectfully submitted,\n\n/s/ Christian R. Everdell\n\nMark S. Cohen\nChristian R. Everdell\nCOHEN & GRESSER LLP\n800 Third Avenue, 21st Floor\nNew York, New York 10022\n(212) 957-7600\n\ncc: All counsel of record (via ECF)\n\n3 The defense recently learned that some of these prison guards were, in fact, BOP psychologists who were observing Ms. Maxwell and evaluating her for hours each day without her knowledge. We are aware of no other pretrial detainee receiving such treatment.\n\n4 In our original letter, the defense asked the Court to order the BOP to release Ms. Maxwell into the general population because we had been informed that Ms. Maxwell would not receive certain privileges, like access to a desk and the prison commissary, unless she were housed there. As long as Ms. Maxwell is monitored in the same manner, and receives the same privileges as other pretrial detainees, it is not necessary to move her to the general population.\n\nDOJ-OGR-00001728",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 42 Filed 08/17/20 Page 5 of 5",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "The Honorable Alison J. Nathan\nAugust 17, 2020\nPage 5",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "under constant observation by multiple prison guards.3 She is also still being awakened several times in the middle of the night. Even on more routine matters, Ms. Maxwell's treatment has been worse than other pretrial detainees. For example, Ms. Maxwell has no access to email and has been given 30 minutes per month for personal phone calls, far fewer than the 500 minutes granted to other pretrial detainees since the COVID-19 crisis. Unlike defendants in the general population, she does not have a desk or a writing surface where she can take notes when reviewing the discovery. And until recently, Ms. Maxwell was denied access to the prison commissary for no apparent reason.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "We respect that the BOP needs to ensure the orderly operation of the MDC. But Ms. Maxwell's conditions of confinement are unique to her and seem punitive rather than anything necessary to ensure that the MDC as a whole is running smoothly. Accordingly, we respectfully request that, going forward, Ms. Maxwell be monitored in the same manner as other pretrial detainees and that the Court order the BOP to grant Ms. Maxwell the same privileges given to other detainees.4",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "*   *   *",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "For the reasons set forth above, we respectfully submit that the Court should grant Ms. Maxwell's motion.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Respectfully submitted,\n\n/s/ Christian R. Everdell\n\nMark S. Cohen\nChristian R. Everdell\nCOHEN & GRESSER LLP\n800 Third Avenue, 21st Floor\nNew York, New York 10022\n(212) 957-7600",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "cc: All counsel of record (via ECF)",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "3 The defense recently learned that some of these prison guards were, in fact, BOP psychologists who were observing Ms. Maxwell and evaluating her for hours each day without her knowledge. We are aware of no other pretrial detainee receiving such treatment.",
      "position": "footnote"
    },
    {
      "type": "printed",
      "content": "4 In our original letter, the defense asked the Court to order the BOP to release Ms. Maxwell into the general population because we had been informed that Ms. Maxwell would not receive certain privileges, like access to a desk and the prison commissary, unless she were housed there. As long as Ms. Maxwell is monitored in the same manner, and receives the same privileges as other pretrial detainees, it is not necessary to move her to the general population.",
      "position": "footnote"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00001728",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ms. Maxwell",
      "Mark S. Cohen",
      "Christian R. Everdell"
    ],
    "organizations": [
      "COHEN & GRESSER LLP",
      "BOP",
      "MDC"
    ],
    "locations": [
      "New York"
    ],
    "dates": [
      "August 17, 2020"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "Document 42",
      "DOJ-OGR-00001728"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Ms. Maxwell, discussing her treatment in detention and requesting certain privileges. The document is well-formatted and free of significant damage or redactions."
}