{
  "document_metadata": {
    "page_number": "5",
    "document_number": "408",
    "date": "11/03/21",
    "document_type": "Court Document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 408 Filed 11/03/21 Page 5 of 7\nLAW OFFICES OF BOBBI C. STERNHEIM\n\nLittle has been done to improve Ms. Maxwell's situation, despite repeated disclosures by counsel. Neither the Court nor the government welcomes these issues but there is no recourse except to raise and expose Ms. Maxwell's inappropriate conditions of confinement and the daily problems that counsel must navigate as the sole advocates for Ms. Maxwell.5\n\nAs the trial draws near, we urge the Court to release Ms. Maxwell on the extremely restrictive conditions previously proposed and any additional conditions that the Court deems necessary. There is no factual or legal basis to conclude that no conditions exist to ensure Ms. Maxwell's appearance at trial.\n\nIf Ms. Maxwell is subject to the situation she was forced to endure on April 23, 2021, the day of her arraignment on the superseding indictment, and again yesterday, there is serious concern that she will be further diminished physically, rendering her unable to withstand the rigors of trial might render her incapable of attending her own trial. On April 23, she was awakened at approximately 3:00 a.m., transported to the courthouse, kept in the cellblock from approximately 5:00 am to approximately 2:00 p.m., when she was brought to the courtroom holding cell. For the entire day she was provided inadequate food and liquid, was not permitted to retain and review her legal materials and was kept shackled on a metal bench in an excessively cold cell. This past Monday, she was awakened at 3:45 a.m. and given a brown bag with two small apples, two small containers of milk and a cup of cereal but no utensils. She was not permitted to bring a sweatshirt for warmth. She was transported to the courthouse by two marshals. Her leg shackles and arm restraints prevented her from raising her feet to enter the van upright, requiring her to climb into the van on hands and knees. She arrived at the courthouse at\n\n5 Regarding the ongoing issue concerning receipt of legal mail and disclosures from the government, yesterday afternoon - November 2 - Ms. Maxwell received two discs and a hard drive containing many hundreds of pages of witness materials, exhibits and other discovery mailed by the government with cover letters dated October 26 and October 29, corresponding to the same disclosure made to counsel on October 25 and October 28.\n\n5\nDOJ-OGR-00006060",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 408 Filed 11/03/21 Page 5 of 7",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "LAW OFFICES OF BOBBI C. STERNHEIM",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Little has been done to improve Ms. Maxwell's situation, despite repeated disclosures by counsel. Neither the Court nor the government welcomes these issues but there is no recourse except to raise and expose Ms. Maxwell's inappropriate conditions of confinement and the daily problems that counsel must navigate as the sole advocates for Ms. Maxwell.5",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "As the trial draws near, we urge the Court to release Ms. Maxwell on the extremely restrictive conditions previously proposed and any additional conditions that the Court deems necessary. There is no factual or legal basis to conclude that no conditions exist to ensure Ms. Maxwell's appearance at trial.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "If Ms. Maxwell is subject to the situation she was forced to endure on April 23, 2021, the day of her arraignment on the superseding indictment, and again yesterday, there is serious concern that she will be further diminished physically, rendering her unable to withstand the rigors of trial might render her incapable of attending her own trial. On April 23, she was awakened at approximately 3:00 a.m., transported to the courthouse, kept in the cellblock from approximately 5:00 am to approximately 2:00 p.m., when she was brought to the courtroom holding cell. For the entire day she was provided inadequate food and liquid, was not permitted to retain and review her legal materials and was kept shackled on a metal bench in an excessively cold cell. This past Monday, she was awakened at 3:45 a.m. and given a brown bag with two small apples, two small containers of milk and a cup of cereal but no utensils. She was not permitted to bring a sweatshirt for warmth. She was transported to the courthouse by two marshals. Her leg shackles and arm restraints prevented her from raising her feet to enter the van upright, requiring her to climb into the van on hands and knees. She arrived at the courthouse at",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "5 Regarding the ongoing issue concerning receipt of legal mail and disclosures from the government, yesterday afternoon - November 2 - Ms. Maxwell received two discs and a hard drive containing many hundreds of pages of witness materials, exhibits and other discovery mailed by the government with cover letters dated October 26 and October 29, corresponding to the same disclosure made to counsel on October 25 and October 28.",
      "position": "footnote"
    },
    {
      "type": "printed",
      "content": "5",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00006060",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Ms. Maxwell",
      "Bobbi C. Sternheim"
    ],
    "organizations": [
      "LAW OFFICES OF BOBBI C. STERNHEIM",
      "government"
    ],
    "locations": [
      "courthouse"
    ],
    "dates": [
      "April 23, 2021",
      "November 2",
      "October 26",
      "October 29",
      "October 25",
      "October 28",
      "11/03/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "408",
      "DOJ-OGR-00006060"
    ]
  },
  "additional_notes": "The document appears to be a court filing discussing the conditions of confinement for Ms. Maxwell. The text is mostly printed, with a footnote and some header/footer information. There are no visible stamps or handwritten text."
}