{
  "document_metadata": {
    "page_number": "1",
    "document_number": "346",
    "date": "10/14/21",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 346 Filed 10/14/21 Page 1 of 3\nLAW OFFICES OF BOBBI C. STERNHEIM\n212-243-1100 · Main\n917-912-9698 · Cell\n888-587-4737 · Fax\n225 Broadway, Suite 715\nNew York, NY 10007\nbcsternheim@mac.com\nOctober 14, 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:\nI respectfully request that the Court issue an order directing the MDC to provide to Ms. Maxwell all legal mail, including mailings sent or hand-delivered by counsel and the government, within one day of receipt by the MDC. A hard drive containing Court-ordered disclosures (3500 material, non-testifying witness materials, and the Government's proffered exhibits) was sent via FedEx by the Government on October 11 and received by the MDC on October 12. The hard drive was not provided to Ms. Maxwell until late morning today, October 14.\nThis is but the latest episode in the persistent practice by MDC of delaying delivery to Ms. Maxwell of critical legal materials sent to the MDC via FedEx and/or the U.S. Postal Service or hand-delivered and deposited by counsel in the legal mailbox. Legal mail deposited in the MDC legal mailbox on October 2 was not discovered by the MDC until October 7, after staff insinuated that Ms. Maxwell's counsel had not deposited it in the mailbox. When finally discovered, a questionable bar code sticker was attached to the envelope that was not affixed by counsel or familiar to MDC staff, suggesting that it had been tampered with. This was brought to the attention of the Warden. The Unit Manager contacted counsel regarding this irregularity and personally returned the legal mail to counsel on October 9. These ongoing delays have interfered with Ms. Maxwell's ability to prepare for trial and to confer with\nDOJ-OGR-00005229",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 346 Filed 10/14/21 Page 1 of 3",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "LAW OFFICES OF BOBBI C. STERNHEIM",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "212-243-1100 · Main\n917-912-9698 · Cell\n888-587-4737 · Fax\n225 Broadway, Suite 715\nNew York, NY 10007\nbcsternheim@mac.com",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "October 14, 2021",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Honorable Alison J. Nathan\nUnited States District Judge\nUnited States Courthouse\n40 Foley Square\nNew York, NY 10007",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Re: United States v. Ghislaine Maxwell\nS2 20 Cr. 330 (AJN)",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Dear Judge Nathan:\nI respectfully request that the Court issue an order directing the MDC to provide to Ms. Maxwell all legal mail, including mailings sent or hand-delivered by counsel and the government, within one day of receipt by the MDC. A hard drive containing Court-ordered disclosures (3500 material, non-testifying witness materials, and the Government's proffered exhibits) was sent via FedEx by the Government on October 11 and received by the MDC on October 12. The hard drive was not provided to Ms. Maxwell until late morning today, October 14.\nThis is but the latest episode in the persistent practice by MDC of delaying delivery to Ms. Maxwell of critical legal materials sent to the MDC via FedEx and/or the U.S. Postal Service or hand-delivered and deposited by counsel in the legal mailbox. Legal mail deposited in the MDC legal mailbox on October 2 was not discovered by the MDC until October 7, after staff insinuated that Ms. Maxwell's counsel had not deposited it in the mailbox. When finally discovered, a questionable bar code sticker was attached to the envelope that was not affixed by counsel or familiar to MDC staff, suggesting that it had been tampered with. This was brought to the attention of the Warden. The Unit Manager contacted counsel regarding this irregularity and personally returned the legal mail to counsel on October 9. These ongoing delays have interfered with Ms. Maxwell's ability to prepare for trial and to confer with",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00005229",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ghislaine Maxwell",
      "Bobbi C. Sternheim"
    ],
    "organizations": [
      "Law Offices of Bobbi C. Sternheim",
      "United States District Judge",
      "United States Courthouse",
      "MDC",
      "FedEx",
      "U.S. Postal Service"
    ],
    "locations": [
      "New York",
      "NY",
      "Broadway"
    ],
    "dates": [
      "October 14, 2021",
      "October 11",
      "October 12",
      "October 14",
      "October 2",
      "October 7",
      "October 9"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 346",
      "S2 20 Cr. 330 (AJN)",
      "DOJ-OGR-00005229"
    ]
  },
  "additional_notes": "The document appears to be a formal letter from Bobbi C. Sternheim to Honorable Alison J. Nathan regarding issues with the delivery of legal mail to Ghislaine Maxwell. The document is typed and contains no handwritten text or stamps."
}