{
  "document_metadata": {
    "page_number": "51",
    "document_number": "670",
    "date": "06/22/22",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 670 Filed 06/22/22 Page 51 of 55\nbetween the defendant's prior life and the life of an inmate may feel extreme to the defendant, but when compared to the experiences of other pretrial detainees in this District, her experience is by no means so shocking as to merit a downward variance.\nIf anything, the defendant's privilege remained intact while at the MDC, as demonstrated by the exceptional benefits she received. No other inmate received the kind of access to discovery and to counsel that the defendant did. The defendant had her own shower, her own television, her own desktop computer, her own laptop, and her own space to spend the day outside of her cell.\nThe defendant was able to get any concerns, no matter how small, immediately brought to the attention of MDC legal counsel through her attorneys. Comparing that treatment to SAMS is out of touch with reality. In many respects, the defendant's conditions of confinement were preferential and more beneficial than those experienced by other inmates.\nTellingly, the defendant's complaints about the MDC seem internally inconsistent. On the one hand, she complains that she was removed from general population. On the other hand, she claims that she should not have been moved abruptly into general population after the conclusion of her trial.9 On the one hand, she claims that she would have had more freedom in general population. On the other hand, she asks the Court for a lesser sentence because the general population lost visitation and was locked into their cells for excessive periods because of COVID-19. On the one hand, she complains that a camera was always on her. On the other hand, she\n9 The defendant also makes the sensational claim that she was the target of a \"credible death threat.\" (Dkt. No. 663 at 7). The Government has conferred with legal counsel for the MDC and has been informed that the MDC conducted an internal investigation of the purported threat and determined the following: an inmate at the MDC remarked to someone in passing, in sum and substance, \"I'd kill her if someone paid me a million dollars.\" Someone else overheard that remark and reported it, resulting in the inmate being moved out of the housing unit. The MDC's investigation revealed that the inmate had not actually been paid to kill the defendant and had not actually threatened Maxwell.\n49\nDOJ-OGR-00010586",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 670 Filed 06/22/22 Page 51 of 55",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "between the defendant's prior life and the life of an inmate may feel extreme to the defendant, but when compared to the experiences of other pretrial detainees in this District, her experience is by no means so shocking as to merit a downward variance.\nIf anything, the defendant's privilege remained intact while at the MDC, as demonstrated by the exceptional benefits she received. No other inmate received the kind of access to discovery and to counsel that the defendant did. The defendant had her own shower, her own television, her own desktop computer, her own laptop, and her own space to spend the day outside of her cell.\nThe defendant was able to get any concerns, no matter how small, immediately brought to the attention of MDC legal counsel through her attorneys. Comparing that treatment to SAMS is out of touch with reality. In many respects, the defendant's conditions of confinement were preferential and more beneficial than those experienced by other inmates.\nTellingly, the defendant's complaints about the MDC seem internally inconsistent. On the one hand, she complains that she was removed from general population. On the other hand, she claims that she should not have been moved abruptly into general population after the conclusion of her trial.9 On the one hand, she claims that she would have had more freedom in general population. On the other hand, she asks the Court for a lesser sentence because the general population lost visitation and was locked into their cells for excessive periods because of COVID-19. On the one hand, she complains that a camera was always on her. On the other hand, she",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "9 The defendant also makes the sensational claim that she was the target of a \"credible death threat.\" (Dkt. No. 663 at 7). The Government has conferred with legal counsel for the MDC and has been informed that the MDC conducted an internal investigation of the purported threat and determined the following: an inmate at the MDC remarked to someone in passing, in sum and substance, \"I'd kill her if someone paid me a million dollars.\" Someone else overheard that remark and reported it, resulting in the inmate being moved out of the housing unit. The MDC's investigation revealed that the inmate had not actually been paid to kill the defendant and had not actually threatened Maxwell.",
      "position": "footnote"
    },
    {
      "type": "printed",
      "content": "49",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00010586",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Maxwell"
    ],
    "organizations": [
      "MDC",
      "Government",
      "Court"
    ],
    "locations": [
      "District"
    ],
    "dates": [
      "06/22/22"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 670",
      "Dkt. No. 663",
      "DOJ-OGR-00010586"
    ]
  },
  "additional_notes": "The document appears to be a court filing discussing the conditions of confinement for a defendant at the MDC. The text is printed and there are no visible stamps or handwritten notes. The document is from a legal case with the reference number 1:20-cr-00330-PAE."
}