{
  "document_metadata": {
    "page_number": "3",
    "document_number": "91",
    "date": "12/07/20",
    "document_type": "Letter",
    "has_handwriting": true,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-000330-AJN Document 91 Filed 12/07/20 Page 3 of 10\n\nLAW OFFICES OF BOBBI C. STERNHEIM\n\nyou will recall, after he committed suicide, I said that I was confident that we would continue to pursue this case vigorously and pursue anyone who's complicit in it. And so I'm very happy that we were able to get Ms. Maxwell.\"\n\nA source said the BOP is taking extra preventative measures to regain the public's trust and confidence as well as preserving the integrity of the Justice Department.1\n\nIt is obvious that Ms. Maxwell is bearing the brunt of BOP incompetence. Being \"livid\" over the death of Epstein, the Department of Justice is seeking to repair the BOP's tarnished reputation by placing Ms. Maxwell under extraordinarily harsh conditions, not in any response to Ms. Maxwell's requirements, but rather in response to the failed handling of a completely different inmate.\n\nMs. Maxwell has been an exemplary detainee. The psychological and physiological impact of solitary isolation is well documented. Ms. Maxwell has not, by her conduct or by virtue of the charges, brought this type of overly restrictive confinement upon herself. The conditions under which she is detained are punitive, unwarranted, deleteriously impacting her ability to prepare her defense, and interfering with counsel's ability to provide the legal representation to which she, and any other detainee, deserves.\n\nThe MDC's letter is insufficient. The warden of the institution bears responsibility for the conditions under which Ms. Maxwell is confined. Warden Tellez should be directed to respond to the numerous concerns that have been brought to his attention.\n\nVery truly yours,\n\nBobbi C. Sternheim\nBOBBI C. STERNHEIM\n\nEnc.\ncc: All Counsel\nMs. Sophia Papapetru\nMr. John Wallace\n\n1 https://abcnews.go.com/US/ghislaine-maxwell-paper-clothes-correctional-center-avoid-suicide/story?id=71699000 (emphasis added).\n\n3\nDOJ-OGR-00001868",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-000330-AJN Document 91 Filed 12/07/20 Page 3 of 10",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "LAW OFFICES OF BOBBI C. STERNHEIM",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "you will recall, after he committed suicide, I said that I was confident that we would continue to pursue this case vigorously and pursue anyone who's complicit in it. And so I'm very happy that we were able to get Ms. Maxwell.\"",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "A source said the BOP is taking extra preventative measures to regain the public's trust and confidence as well as preserving the integrity of the Justice Department.1",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "It is obvious that Ms. Maxwell is bearing the brunt of BOP incompetence. Being \"livid\" over the death of Epstein, the Department of Justice is seeking to repair the BOP's tarnished reputation by placing Ms. Maxwell under extraordinarily harsh conditions, not in any response to Ms. Maxwell's requirements, but rather in response to the failed handling of a completely different inmate.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Ms. Maxwell has been an exemplary detainee. The psychological and physiological impact of solitary isolation is well documented. Ms. Maxwell has not, by her conduct or by virtue of the charges, brought this type of overly restrictive confinement upon herself. The conditions under which she is detained are punitive, unwarranted, deleteriously impacting her ability to prepare her defense, and interfering with counsel's ability to provide the legal representation to which she, and any other detainee, deserves.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The MDC's letter is insufficient. The warden of the institution bears responsibility for the conditions under which Ms. Maxwell is confined. Warden Tellez should be directed to respond to the numerous concerns that have been brought to his attention.",
      "position": "middle"
    },
    {
      "type": "handwritten",
      "content": "Bobbi C. Sternheim",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "BOBBI C. STERNHEIM",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "Enc.\ncc: All Counsel\nMs. Sophia Papapetru\nMr. John Wallace",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "1 https://abcnews.go.com/US/ghislaine-maxwell-paper-clothes-correctional-center-avoid-suicide/story?id=71699000 (emphasis added).",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "3\nDOJ-OGR-00001868",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Bobbi C. Sternheim",
      "Ms. Maxwell",
      "Epstein",
      "Warden Tellez",
      "Ms. Sophia Papapetru",
      "Mr. John Wallace"
    ],
    "organizations": [
      "BOP",
      "Department of Justice",
      "MDC"
    ],
    "locations": [],
    "dates": [
      "12/07/20"
    ],
    "reference_numbers": [
      "1:20-cr-000330-AJN",
      "91",
      "DOJ-OGR-00001868"
    ]
  },
  "additional_notes": "The document appears to be a letter from Bobbi C. Sternheim to an unspecified recipient, discussing the case of Ms. Maxwell and her detention conditions. The letter is typed, with a handwritten signature. There are no visible stamps or annotations."
}