{
  "document_metadata": {
    "page_number": "1",
    "document_number": "91",
    "date": "12/07/20",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 91 Filed 12/07/20 Page 1 of 10\nLAW OFFICES OF BOBBI C. STERNHEIM\n212-243-1100 • Main 917-306-6666 • Cell 888-587-4737 • Fax 33 West 19th Street - 4th Floor New York, New York 10011 bc@sternheimlaw.com\nDecember 7, 2020\nBY ECF\nHonorable Alison J. Nathan\nUnited States District Judge\nUnited States Courthouse\n40 Foley Square\nNew York, NY 10007\nRe: United States v. Ghislaine Maxwell 20 Cr. 330 (AJN)\nDear Judge Nathan:\nAs counsel for Ghislaine Maxwell, we write in response to the letter from Sophia Papapetru and John Wallace, MDC staff attorneys. (See Dkt. 88.) The letter fails to address a number of concerns raised in our October 29th letter to Warden Heriberto Tellez and raised with the Court. The MDC's letter also contains inaccuracies and omissions and raises more questions than it attempts to answer. Rather than paraphrase our letter, we are providing it for the Court's consideration. (See Exhibit A.) We renew our request that Warden Tellez respond directly to the Court and counsel and explain why Ms. Maxwell must be detained under such harsh and restrictive conditions.\nUsing the term \"[i]n her current assignment,\" the letter attempts to present a picture of compliance with total disregard of the deficiencies of Ms. Maxwell's treatment up to this point. While her meals may currently be in accordance with BOP policy, until September they were not. While her weight may currently be fairly consistent, she had lost over 15 pounds, and she is sustaining hair loss. It took approximately six weeks following arrival to the MDC for Ms. Maxwell to be permitted personal calls on par with other inmates; previously she was given two calls per month unless authorized by the warden. While generally permitted to be out of her isolation cell and confined to the day room from 7:00 am to 8:00 pm with one hour of recreation time, general population inmates are permitted to be out of their cells until 9:30 pm and given more extensive recreation time. While flashlight checks may be performed during regular rounds, Ms. Maxwell is subject to such checks every 15 minutes. Further, because Ms. Maxwell is kept in isolation, she in not permitted to participate in activities accorded inmates in general population, such as programming (educational, leisure and wellness), movies, religious services, job assignment.\nTouting that Ms. Maxwell is not in contact with \"a number of inmates who have tested positive for COVID-19,\" the MDC's letter totally ignores that she was in contact with a member of her revolving security team who tested positive, necessitating that Ms. Maxwell be quarantined for 14 days. This further diminished her ability to prepare her defense and resulted in cancelled legal visits. While the letter accurately states that one video teleconference (VTC) was\nDOJ-OGR-00001866",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 91 Filed 12/07/20 Page 1 of 10",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "LAW OFFICES OF BOBBI C. STERNHEIM",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "212-243-1100 • Main 917-306-6666 • Cell 888-587-4737 • Fax 33 West 19th Street - 4th Floor New York, New York 10011 bc@sternheimlaw.com",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "December 7, 2020",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "BY ECF",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Honorable Alison J. Nathan\nUnited States District Judge\nUnited States Courthouse\n40 Foley Square\nNew York, NY 10007",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Re: United States v. Ghislaine Maxwell 20 Cr. 330 (AJN)",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Dear Judge Nathan:",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "As counsel for Ghislaine Maxwell, we write in response to the letter from Sophia Papapetru and John Wallace, MDC staff attorneys. (See Dkt. 88.) The letter fails to address a number of concerns raised in our October 29th letter to Warden Heriberto Tellez and raised with the Court. The MDC's letter also contains inaccuracies and omissions and raises more questions than it attempts to answer. Rather than paraphrase our letter, we are providing it for the Court's consideration. (See Exhibit A.) We renew our request that Warden Tellez respond directly to the Court and counsel and explain why Ms. Maxwell must be detained under such harsh and restrictive conditions.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Using the term \"[i]n her current assignment,\" the letter attempts to present a picture of compliance with total disregard of the deficiencies of Ms. Maxwell's treatment up to this point. While her meals may currently be in accordance with BOP policy, until September they were not. While her weight may currently be fairly consistent, she had lost over 15 pounds, and she is sustaining hair loss. It took approximately six weeks following arrival to the MDC for Ms. Maxwell to be permitted personal calls on par with other inmates; previously she was given two calls per month unless authorized by the warden. While generally permitted to be out of her isolation cell and confined to the day room from 7:00 am to 8:00 pm with one hour of recreation time, general population inmates are permitted to be out of their cells until 9:30 pm and given more extensive recreation time. While flashlight checks may be performed during regular rounds, Ms. Maxwell is subject to such checks every 15 minutes. Further, because Ms. Maxwell is kept in isolation, she in not permitted to participate in activities accorded inmates in general population, such as programming (educational, leisure and wellness), movies, religious services, job assignment.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Touting that Ms. Maxwell is not in contact with \"a number of inmates who have tested positive for COVID-19,\" the MDC's letter totally ignores that she was in contact with a member of her revolving security team who tested positive, necessitating that Ms. Maxwell be quarantined for 14 days. This further diminished her ability to prepare her defense and resulted in cancelled legal visits. While the letter accurately states that one video teleconference (VTC) was",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00001866",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ghislaine Maxwell",
      "Sophia Papapetru",
      "John Wallace",
      "Heriberto Tellez"
    ],
    "organizations": [
      "LAW OFFICES OF BOBBI C. STERNHEIM",
      "United States District Judge",
      "United States Courthouse",
      "MDC"
    ],
    "locations": [
      "New York",
      "40 Foley Square"
    ],
    "dates": [
      "December 7, 2020",
      "October 29th",
      "September"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "Document 91",
      "20 Cr. 330 (AJN)",
      "Dkt. 88",
      "DOJ-OGR-00001866"
    ]
  },
  "additional_notes": "The document appears to be a formal letter from the Law Offices of Bobbi C. Sternheim to Honorable Alison J. Nathan, United States District Judge. The letter is regarding the case of United States v. Ghislaine Maxwell (20 Cr. 330). The document is well-formatted and printed, with no visible handwriting or stamps."
}