{
  "document_metadata": {
    "page_number": "5",
    "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 5 of 10\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\nOctober 29, 2020\nVia Email/Regular Mail\nWarden Heriberto Tellez\nMetropolitan Detention Center\nOffice of the Warden\n80 29th Street\nBrooklyn, New York 11232\nRe: Ghislaine Maxwell 02879-509\nDear Warden Tellez:\nAs counsel for Ghislaine Maxwell, we again seek your urgent attention concerning issues related to conditions of her detention at the MDC.1 Our immediate goal is to rectify these problems and improve the extraordinarily restrictive conditions under which Ms. Maxwell is presently confined within your facility.\nOn July 14, 2020, the Honorable Alison J. Nathan entered an order of detention remanding Ghislaine Maxwell to the custody of the Bureau of Prisons. She has been detained since her arrest on July 2, 2020 and has been incarcerated at MDC under conditions that rival those at USP Florence ADMAX. An exemplary inmate who poses no threat to her personal safety or danger to anyone, she has spent the entirety of her detention in de facto solitary confinement, tantamount to imprisonment as a defendant convicted of capital murder and incarcerated on death row. The conditions of her detention are utterly inappropriate, especially so for a non-violent defendant with no prior criminal history facing non-violent charges a quarter-century old.\nWithout a doubt, the BOP has imposed extraordinarily onerous conditions of constraint on Ms. Maxwell to avoid the catastrophic consequences of negligence occurring at the Metropolitan Correctional Center (MCC- Manhattan) which resulted in the death of Jeffrey Epstein. The Attorney General of the United States has said as much. The BOP has admitted that the sanctions are not in response to a specific threat that Ms. Maxwell has shown; rather they are in response to the high-profile nature of the case and the acknowledged failure by the BOP to keep Epstein - an actual threat to himself - alive. Ms. Maxwell is bearing the brunt of incompetence on MCC's watch. As ABC News reported:\n1 Previous letters were sent to you on August 28, 2020 and September 9, 2020.\nDOJ-OGR-00001870",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 91 Filed 12/07/20 Page 5 of 10",
      "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",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "33 West 19th Street - 4th Floor\nNew York, New York 10011\nbc@sternheimlaw.com",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "October 29, 2020",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Via Email/Regular Mail",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Warden Heriberto Tellez\nMetropolitan Detention Center\nOffice of the Warden\n80 29th Street\nBrooklyn, New York 11232",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Re: Ghislaine Maxwell 02879-509",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Dear Warden Tellez:",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "As counsel for Ghislaine Maxwell, we again seek your urgent attention concerning issues related to conditions of her detention at the MDC.1 Our immediate goal is to rectify these problems and improve the extraordinarily restrictive conditions under which Ms. Maxwell is presently confined within your facility.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "On July 14, 2020, the Honorable Alison J. Nathan entered an order of detention remanding Ghislaine Maxwell to the custody of the Bureau of Prisons. She has been detained since her arrest on July 2, 2020 and has been incarcerated at MDC under conditions that rival those at USP Florence ADMAX. An exemplary inmate who poses no threat to her personal safety or danger to anyone, she has spent the entirety of her detention in de facto solitary confinement, tantamount to imprisonment as a defendant convicted of capital murder and incarcerated on death row. The conditions of her detention are utterly inappropriate, especially so for a non-violent defendant with no prior criminal history facing non-violent charges a quarter-century old.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Without a doubt, the BOP has imposed extraordinarily onerous conditions of constraint on Ms. Maxwell to avoid the catastrophic consequences of negligence occurring at the Metropolitan Correctional Center (MCC- Manhattan) which resulted in the death of Jeffrey Epstein. The Attorney General of the United States has said as much. The BOP has admitted that the sanctions are not in response to a specific threat that Ms. Maxwell has shown; rather they are in response to the high-profile nature of the case and the acknowledged failure by the BOP to keep Epstein - an actual threat to himself - alive. Ms. Maxwell is bearing the brunt of incompetence on MCC's watch. As ABC News reported:",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "1 Previous letters were sent to you on August 28, 2020 and September 9, 2020.",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00001870",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Ghislaine Maxwell",
      "Heriberto Tellez",
      "Alison J. Nathan",
      "Jeffrey Epstein",
      "Bobbi C. Sternheim"
    ],
    "organizations": [
      "LAW OFFICES OF BOBBI C. STERNHEIM",
      "Metropolitan Detention Center",
      "Bureau of Prisons",
      "USP Florence ADMAX",
      "Metropolitan Correctional Center",
      "ABC News"
    ],
    "locations": [
      "New York",
      "Brooklyn",
      "Manhattan"
    ],
    "dates": [
      "October 29, 2020",
      "July 14, 2020",
      "July 2, 2020",
      "August 28, 2020",
      "September 9, 2020",
      "12/07/20"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "91",
      "02879-509",
      "DOJ-OGR-00001870"
    ]
  },
  "additional_notes": "The document appears to be a formal letter from the Law Offices of Bobbi C. Sternheim to Warden Heriberto Tellez regarding the detention conditions of Ghislaine Maxwell. The letter is typed and contains no handwritten text or stamps."
}