{
  "document_metadata": {
    "page_number": "2 of 2",
    "document_number": "75",
    "date": "11/24/20",
    "document_type": "Letter",
    "has_handwriting": true,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 75 Filed 11/24/20 Page 2 of 2\nLAW OFFICES OF BOBBI C. STERNHEIM\nThe government highlights what Ms. Maxwell is permitted but not what she is denied: equal treatment accorded other inmates in general population. Ms. Maxwell has spent the entirely of her pretrial detention in de facto solitary confinement under the most restrictive conditions where she is excessively and invasively searched and is monitored 24 hours per day. In addition to camera surveillance in her cell, a supplemental camera follows her movement when she is permitted to leave her isolation cell and is focused on Ms. Maxwell and counsel during in-person legal visits. And despite non-stop in-cell camera surveillance, Ms. Maxwell's sleep is disrupted every 15-minutes when she is awakened by a flashlight to ascertain whether she is breathing.\nMs. Maxwell is a non-violent, exemplary pretrial detainee with no criminal history, no history of violence, no history of mental health issues or suicidal ideation. She is overmanaged under conditions more restrictive than inmates housed in 10South, the most restrictive unit in the MCC; or individuals convicted of terrorism and capital murder and incarcerated at FCI Florence ADMAX, the most restrictive facility operated by the BOP. The MDC concedes that it is unable to place her in general population for her safety and the security of the institution but fails to explain why she is deprived of all other opportunities provided to general population inmates.\nStating that Ms. Maxwell \"continues to have more time to review her discovery than any other inmate at the MDC, even while in quarantine\" gives the unfair impression that she is being given a perquisite. However, given the voluminous discovery in this case, the most recent production alone being 1.2 million documents, the time accorded Ms. Maxwell remains inadequate for her to review and prepare the defense of her life.\nDue to the failure of MDC's Warden and Legal Department to respond to recurring problems and complaints, counsel have reached out to the government. While we appreciate any assistance provided by government counsel, it has done little to redress the many concerns regarding the disparate treatment of Ms. Maxwell.\nRather than receive second-hand information from counsel, the defense requests that the Court summon Warden Heriberto Tellez to report directly to the Court and counsel on Ms. Maxwell's conditions of detention.\nYour consideration is greatly appreciated.\nVery truly yours,\nBobbi C. Sternheim\nBOBBI C. STERNHEIM\ncc: All Counsel\n2\nDOJ-OGR-00001838",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 75 Filed 11/24/20 Page 2 of 2",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "LAW OFFICES OF BOBBI C. STERNHEIM",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "The government highlights what Ms. Maxwell is permitted but not what she is denied: equal treatment accorded other inmates in general population. Ms. Maxwell has spent the entirely of her pretrial detention in de facto solitary confinement under the most restrictive conditions where she is excessively and invasively searched and is monitored 24 hours per day. In addition to camera surveillance in her cell, a supplemental camera follows her movement when she is permitted to leave her isolation cell and is focused on Ms. Maxwell and counsel during in-person legal visits. And despite non-stop in-cell camera surveillance, Ms. Maxwell's sleep is disrupted every 15-minutes when she is awakened by a flashlight to ascertain whether she is breathing.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Ms. Maxwell is a non-violent, exemplary pretrial detainee with no criminal history, no history of violence, no history of mental health issues or suicidal ideation. She is overmanaged under conditions more restrictive than inmates housed in 10South, the most restrictive unit in the MCC; or individuals convicted of terrorism and capital murder and incarcerated at FCI Florence ADMAX, the most restrictive facility operated by the BOP. The MDC concedes that it is unable to place her in general population for her safety and the security of the institution but fails to explain why she is deprived of all other opportunities provided to general population inmates.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Stating that Ms. Maxwell \"continues to have more time to review her discovery than any other inmate at the MDC, even while in quarantine\" gives the unfair impression that she is being given a perquisite. However, given the voluminous discovery in this case, the most recent production alone being 1.2 million documents, the time accorded Ms. Maxwell remains inadequate for her to review and prepare the defense of her life.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Due to the failure of MDC's Warden and Legal Department to respond to recurring problems and complaints, counsel have reached out to the government. While we appreciate any assistance provided by government counsel, it has done little to redress the many concerns regarding the disparate treatment of Ms. Maxwell.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Rather than receive second-hand information from counsel, the defense requests that the Court summon Warden Heriberto Tellez to report directly to the Court and counsel on Ms. Maxwell's conditions of detention.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Your consideration is greatly appreciated.",
      "position": "body"
    },
    {
      "type": "handwritten",
      "content": "Bobbi C. Sternheim",
      "position": "signature"
    },
    {
      "type": "printed",
      "content": "Very truly yours,\nBOBBI C. STERNHEIM\ncc: All Counsel",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "2",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00001838",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Ms. Maxwell",
      "Bobbi C. Sternheim",
      "Heriberto Tellez"
    ],
    "organizations": [
      "MDC",
      "MCC",
      "FCI Florence ADMAX",
      "BOP"
    ],
    "locations": [],
    "dates": [
      "11/24/20"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "Document 75",
      "DOJ-OGR-00001838"
    ]
  },
  "additional_notes": "The document appears to be a formal letter from Bobbi C. Sternheim to an unspecified recipient, discussing the conditions of detention for Ms. Maxwell. The letter is typed, with a handwritten signature. There are no visible redactions or damage."
}