{
  "document_metadata": {
    "page_number": "1",
    "document_number": "2256",
    "date": "April 29, 2021",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": true
  },
  "full_text": "LAW 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\nApril 29, 2021\nHonorable Alison J. Nathan\nUnited States District Judge\nUnited States Courthouse\n40 Foley Square\nNew York, NY 10007\nRe: United States v. Ghislaine Maxwell\nS2 20 Cr. 330 (AJN)\nDear Judge Nathan:\nDuring oral argument of Ghislaine Maxwell's bail appeal before the Circuit, Ms. Maxwell's appellate counsel expressed concern that she was improperly deprived of sleep while detained in the MDC, an issue that has been raised in filings before this Court. In its brief denial of her appeal, the Circuit stated: \"To the extent Appellant seeks relief specific to her sleeping conditions, such request should be addressed to the District Court.\" See Exhibit A. We press our concerns regarding disruption of Ms. Maxwell's sleep and the deleterious effect sleep deprivation is having on her health, well-being, and ability to prepare for and withstand trial.\nMs. Maxwell continues to be disrupted throughout the night by guards shining a flash/strobe light into her cell, claiming that her breathing must be checked. The myth that Ms. Maxwell's conditions of confinement are related to her being a suicide risk was laid to rest during the oral argument: There is nothing to support that contrived claim. In fact, Ms. Maxwell is classified with the standard CC1-Mh designation: inmate with no significant mental health care. (See Dkt. 159 at 3.)\nContrary to the report that Ms. Maxwell \"wears an eye mask when she sleeps\" (Dkt. 196 at 4), an item neither available for purchase through MDC commissary nor provided to her, she resorts to using a sock or towel to cover her eyes in an awkward attempt to shield them from disrupting illumination every 15 minutes. Last night, she was confronted by MDC staff due a visible bruise over her left eye. The \"black eye\" is depicted in Exhibit B. Despite 24/7 camera surveillance (except when guards elect to exert authority in an intimidating way off-camera, as they did in Saturday's bathroom incident), no guard addressed the bruise until Ms. Maxwell, who has no mirror, caught a reflection of her aching eye in the glean of a nail clipper. At that point, MDC staff confronted Ms. Maxwell regarding the source of the bruise, threatening to place her in the SHU if she did not reveal how she got it. While Ms. Maxwell is unaware of the cause of the bruise, as reported to medical and psych staff, she has grown increasingly reluctant to report information to the guards for fear of retaliation, discipline, and punitive chores. However, there is concern that the bruise may be related to the need for Ms. Maxwell to shield her eyes from the lights projected into her cell throughout the night.\nUSDC SDNY\nDOCUMENT\nELECTRONICALLY FILED\nDOC #:\nDATE FILED: 4/29/21\nDOJ-OGR-00004058",
  "text_blocks": [
    {
      "type": "printed",
      "content": "LAW OFFICES OF BOBBI C. STERNHEIM",
      "position": "header"
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    {
      "type": "printed",
      "content": "April 29, 2021\nHonorable Alison J. Nathan\nUnited States District Judge\nUnited States Courthouse\n40 Foley Square\nNew York, NY 10007\nRe: United States v. Ghislaine Maxwell\nS2 20 Cr. 330 (AJN)\nDear Judge Nathan:",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "During oral argument of Ghislaine Maxwell's bail appeal before the Circuit, Ms. Maxwell's appellate counsel expressed concern that she was improperly deprived of sleep while detained in the MDC, an issue that has been raised in filings before this Court. In its brief denial of her appeal, the Circuit stated: \"To the extent Appellant seeks relief specific to her sleeping conditions, such request should be addressed to the District Court.\" See Exhibit A. We press our concerns regarding disruption of Ms. Maxwell's sleep and the deleterious effect sleep deprivation is having on her health, well-being, and ability to prepare for and withstand trial.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Ms. Maxwell continues to be disrupted throughout the night by guards shining a flash/strobe light into her cell, claiming that her breathing must be checked. The myth that Ms. Maxwell's conditions of confinement are related to her being a suicide risk was laid to rest during the oral argument: There is nothing to support that contrived claim. In fact, Ms. Maxwell is classified with the standard CC1-Mh designation: inmate with no significant mental health care. (See Dkt. 159 at 3.)",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Contrary to the report that Ms. Maxwell \"wears an eye mask when she sleeps\" (Dkt. 196 at 4), an item neither available for purchase through MDC commissary nor provided to her, she resorts to using a sock or towel to cover her eyes in an awkward attempt to shield them from disrupting illumination every 15 minutes. Last night, she was confronted by MDC staff due a visible bruise over her left eye. The \"black eye\" is depicted in Exhibit B. Despite 24/7 camera surveillance (except when guards elect to exert authority in an intimidating way off-camera, as they did in Saturday's bathroom incident), no guard addressed the bruise until Ms. Maxwell, who has no mirror, caught a reflection of her aching eye in the glean of a nail clipper. At that point, MDC staff confronted Ms. Maxwell regarding the source of the bruise, threatening to place her in the SHU if she did not reveal how she got it. While Ms. Maxwell is unaware of the cause of the bruise, as reported to medical and psych staff, she has grown increasingly reluctant to report information to the guards for fear of retaliation, discipline, and punitive chores. However, there is concern that the bruise may be related to the need for Ms. Maxwell to shield her eyes from the lights projected into her cell throughout the night.",
      "position": "middle"
    },
    {
      "type": "stamp",
      "content": "USDC SDNY\nDOCUMENT\nELECTRONICALLY FILED\nDOC #:\nDATE FILED: 4/29/21",
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    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00004058",
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  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ghislaine Maxwell"
    ],
    "organizations": [
      "LAW OFFICES OF BOBBI C. STERNHEIM",
      "United States District Court",
      "MDC"
    ],
    "locations": [
      "New York",
      "United States Courthouse",
      "40 Foley Square"
    ],
    "dates": [
      "April 29, 2021",
      "4/29/21"
    ],
    "reference_numbers": [
      "S2 20 Cr. 330 (AJN)",
      "Dkt. 159",
      "Dkt. 196",
      "DOJ-OGR-00004058"
    ]
  },
  "additional_notes": "The document is a letter from Bobbi C. Sternheim to Judge Alison J. Nathan regarding the conditions of Ghislaine Maxwell's detention. The letter expresses concerns about Maxwell's sleep deprivation and the treatment she is receiving at the MDC. The document includes a stamp indicating that it was electronically filed with the USDC SDNY on April 29, 2021."
}