{
  "document_metadata": {
    "page_number": "10",
    "document_number": "20-cr-330",
    "date": "April 7, 2021",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 139 Filed 04/07/21 Page 10 of 5\n\nLAW OFFICES OF BOBBI C. STERNHEIM\n\n212-243-1100 • Main\n917-306-6666 • Cell\n888-587-4737 • Fax\n\n33 West 19th Street - 4th Floor\nNew York, New York 10011\nbc@sternheimlaw.com\n\nApril 7, 2021\n\nHonorable Alison J. Nathan\nUnited States District Judge\nUnited States Courthouse\n40 Foley Square\nNew York, NY 10007\n\nRe: United States v. Ghislaine Maxwell\nS2 20 Cr. 330 (AJN)\n\nDear Judge Nathan:\n\nThe government's letter of April 6th is yet another regurgitation of its previous letters regarding Ms. Maxwell's conditions of confinement. No matter how often the government tries to present Ms. Maxwell's detention as superior to other inmates, it continues to miss the mark.\n\nWe stand by our previous responses and reiterate that Ms. Maxwell's detention is unwarranted and overly restrictive. It is tantamount to \"pay-it-forward\" punishment served pretrial.\n\nThe government's letter provides the opportunity to flush out the persistent unsanitary conditions at the MDC, which long predate Ms. Maxwell's detention. This past weekend there was a pervasive stench of sewage in Ms. Maxwell's unit necessitating guards to flush pipes by pouring water down open drains in an effort to trap and disperse gaseous emissions. As guards explained to Ms. Maxwell, there are three drains in the day area, and when the plumbing system goes unused, gases escape from the drains and cause the stench. At times the stench in Ms. Maxwell's isolation cell has been overwhelming due to overflowing of toilets in the cellblock above. Due to lack of privacy, Ms. Maxwell refrains from using the toilet in the isolation cell and, as directed by the guards, she flushes frequently to avoid plumbing problems. At times, the stench is apparent upon entering the visiting area. Of the many defense counsel who visit\n\nDOJ-OGR-00001398",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 139 Filed 04/07/21 Page 10 of 5",
      "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": "April 7, 2021",
      "position": "header"
    },
    {
      "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\nS2 20 Cr. 330 (AJN)",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Dear Judge Nathan:",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "The government's letter of April 6th is yet another regurgitation of its previous letters regarding Ms. Maxwell's conditions of confinement. No matter how often the government tries to present Ms. Maxwell's detention as superior to other inmates, it continues to miss the mark.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "We stand by our previous responses and reiterate that Ms. Maxwell's detention is unwarranted and overly restrictive. It is tantamount to \"pay-it-forward\" punishment served pretrial.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "The government's letter provides the opportunity to flush out the persistent unsanitary conditions at the MDC, which long predate Ms. Maxwell's detention. This past weekend there was a pervasive stench of sewage in Ms. Maxwell's unit necessitating guards to flush pipes by pouring water down open drains in an effort to trap and disperse gaseous emissions. As guards explained to Ms. Maxwell, there are three drains in the day area, and when the plumbing system goes unused, gases escape from the drains and cause the stench. At times the stench in Ms. Maxwell's isolation cell has been overwhelming due to overflowing of toilets in the cellblock above. Due to lack of privacy, Ms. Maxwell refrains from using the toilet in the isolation cell and, as directed by the guards, she flushes frequently to avoid plumbing problems. At times, the stench is apparent upon entering the visiting area. Of the many defense counsel who visit",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00001398",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ghislaine Maxwell",
      "Bobbi C. Sternheim"
    ],
    "organizations": [
      "Law Offices of Bobbi C. Sternheim",
      "United States Courthouse",
      "MDC"
    ],
    "locations": [
      "New York",
      "40 Foley Square"
    ],
    "dates": [
      "April 7, 2021",
      "April 6th"
    ],
    "reference_numbers": [
      "20 Cr. 330 (AJN)",
      "DOJ-OGR-00001398"
    ]
  },
  "additional_notes": "The document appears to be a letter from the Law Offices of Bobbi C. Sternheim to Honorable Alison J. Nathan regarding the conditions of confinement of Ghislaine Maxwell. The letter discusses the unsanitary conditions at the MDC and the detention of Ms. Maxwell."
}