{
  "document_metadata": {
    "page_number": "11",
    "document_number": "171",
    "date": "03/23/21",
    "document_type": "Court Document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 171 Filed 03/23/21 Page 11 of 18\n\nConclusion\n\nThe Court should grant bail for Ms. Maxwell on the extraordinary conditions proposed. Should the Court determine that additional conditions are necessary, Ms. Maxwell is willing to satisfy and abide by those terms as well.\n\nDated: March 16, 2021\n\nRespectfully submitted:\n\nBobbi C. Sternheim\nBobbi C. Sternheim\nLaw Offices of Bobbi C. Sternheim\n33 West 19th Street - 4th Floor\nNew York, NY 10011\nPhone: 212-243-1100\n\nChristian R. Everdell\nCOHEN & GRESSER LLP\n800 Third Avenue\nNew York, NY 10022\nPhone: 212-957-7600\n\nJeffrey S. Pagliuca\nLaura A. Menninger\nHADDON, MORGAN & FOREMAN P.C\n150 East 10th Avenue\nDenver, CO 80203\nPhone: 303-831-7364\n\nAttorneys for Ghislaine Maxwell\n\nMaxwell's guards and a hand-held camera focused on both Ms. Maxwell and counsel. Further, confidential attorney-client communications conducted during video teleconferencing (VTC) are now further compromised by the repositioning of a camera with sensitive audio recording, putting a chill on privileged communication. During VTC conferences, counsel can hear conversation among the guards, so it is likely that the guards, who seem to be writing during those sessions, are able to hear discussions between Ms. Maxwell and counsel. Last night, prior to the filing of defense replies to Ms. Maxwell's pretrial motions, the MDC refused her request to speak with her lawyers to provide information bearing on those filings. Such denial violates the BOP's Program Statement pertaining to providing legal calls upon request of pretrial inmates. See https://www.bop.gov/policy/progstat/7331_004.pdf at par. 24(c). The chronic difficulties related to Ms. Maxwell's review of the millions of documents of electronic discovery are continuing to negatively impact her ability to prepare for a trial that is only a few months away.\n\n10\nDOJ-OGR-00002791",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 171 Filed 03/23/21 Page 11 of 18",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Conclusion",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The Court should grant bail for Ms. Maxwell on the extraordinary conditions proposed. Should the Court determine that additional conditions are necessary, Ms. Maxwell is willing to satisfy and abide by those terms as well.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Dated: March 16, 2021",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Respectfully submitted:\n\nBobbi C. Sternheim\nBobbi C. Sternheim\nLaw Offices of Bobbi C. Sternheim\n33 West 19th Street - 4th Floor\nNew York, NY 10011\nPhone: 212-243-1100\n\nChristian R. Everdell\nCOHEN & GRESSER LLP\n800 Third Avenue\nNew York, NY 10022\nPhone: 212-957-7600\n\nJeffrey S. Pagliuca\nLaura A. Menninger\nHADDON, MORGAN & FOREMAN P.C\n150 East 10th Avenue\nDenver, CO 80203\nPhone: 303-831-7364\n\nAttorneys for Ghislaine Maxwell",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Maxwell's guards and a hand-held camera focused on both Ms. Maxwell and counsel. Further, confidential attorney-client communications conducted during video teleconferencing (VTC) are now further compromised by the repositioning of a camera with sensitive audio recording, putting a chill on privileged communication. During VTC conferences, counsel can hear conversation among the guards, so it is likely that the guards, who seem to be writing during those sessions, are able to hear discussions between Ms. Maxwell and counsel. Last night, prior to the filing of defense replies to Ms. Maxwell's pretrial motions, the MDC refused her request to speak with her lawyers to provide information bearing on those filings. Such denial violates the BOP's Program Statement pertaining to providing legal calls upon request of pretrial inmates. See https://www.bop.gov/policy/progstat/7331_004.pdf at par. 24(c). The chronic difficulties related to Ms. Maxwell's review of the millions of documents of electronic discovery are continuing to negatively impact her ability to prepare for a trial that is only a few months away.",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "10",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00002791",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Ms. Maxwell",
      "Bobbi C. Sternheim",
      "Christian R. Everdell",
      "Jeffrey S. Pagliuca",
      "Laura A. Menninger",
      "Ghislaine Maxwell"
    ],
    "organizations": [
      "Law Offices of Bobbi C. Sternheim",
      "COHEN & GRESSER LLP",
      "HADDON, MORGAN & FOREMAN P.C",
      "BOP",
      "MDC"
    ],
    "locations": [
      "New York",
      "NY",
      "Denver",
      "CO"
    ],
    "dates": [
      "March 16, 2021",
      "03/23/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 171",
      "DOJ-OGR-00002791"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to Ghislaine Maxwell's case, discussing bail conditions and issues with attorney-client communications during video teleconferencing."
}