{
  "document_metadata": {
    "page_number": "1",
    "document_number": "22433",
    "date": "April 26, 2021",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": true
  },
  "full_text": "LAW OFFICES OF BOBBI C. STERNHEIM\n212-243-1100 • Main\n917-306-6666 • Cell\n888-587-4737 • Fax\n33 West 19th Stre\nNew York, N\nbc@st\nApril 26, 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 write to report an incident stemming from an attorney-client conference with Ghislaine Maxwell: Guards on Ms. Maxwell's security detail wrongfully seized and reviewed her confidential legal documents and then intimidated Ms. Maxwell by standing over her as she used the bathroom after threatening her with a disciplinary infraction. This incident has further compromised Ms. Maxwell's ability to prepare for trial, to confer with counsel, and to retain confidential legal documents. In addition, intimidation and humiliation by guards has further exacerbated Ms. Maxwell's feelings of insecurity due to officious power exerted upon her by guards.\nOn Saturday, April 24, 2021, Leah Saffian, Esq. and I attended a pre-scheduled in-person legal conference with Ms. Maxwell in the MDC. The entire 2.5-hour conference was conducted under the constant watch of four to five guards, including a lieutenant, with a camera on a tripod focused on Ms. Maxwell and counsel while recording audio and video, and captured on surveillance cameras affixed within the visiting room. After counsel left the facility, Ms. Maxwell called me to report that her legal papers were confiscated.\nLater that day, I received an email from Sophia Papapetru, MDC legal counsel, which stated:\nIt has been brought to my attention by the staff of MDC Brooklyn that Ms. Maxwell received paperwork that was not in her possession upon entering the legal visiting area. As you are aware, the policies set forth for MDC Brooklyn legal visits do not allow for passing of any material during a legal visit. Due to our policy and procedures, the additional documents that were provided to Ms. Maxwell were confiscated. Those materials were put in an envelope and will be returned to you tomorrow upon your arrival to the institution. Please note, that you may put these documents in the legal mailbox in the lobby of the east building.\nSee Exhibit A.\nUSDC SDNY\nDOCUMENT\nELECTRONICALLY FILED\nDOC #: \nDATE FILED: 4/27/21\nMDC legal counsel is hereby ORDERED to show cause by April 28, 2021 why an order directing the MDC to provide the information requested in this letter to the Defendant's counsel ought not issue. MDC legal counsel shall either docket it on ECF or email the letter to the Court so that the Court can docket it on ECF. Chambers will email a copy of this Order directly to legal counsel for the MDC.\nSO ORDERED.\n4/27/21\nAlison J. Nathan, U.S.D.J.",
  "text_blocks": [
    {
      "type": "printed",
      "content": "LAW OFFICES OF BOBBI C. STERNHEIM",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "April 26, 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:",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "I write to report an incident stemming from an attorney-client conference with Ghislaine Maxwell: Guards on Ms. Maxwell's security detail wrongfully seized and reviewed her confidential legal documents and then intimidated Ms. Maxwell by standing over her as she used the bathroom after threatening her with a disciplinary infraction. This incident has further compromised Ms. Maxwell's ability to prepare for trial, to confer with counsel, and to retain confidential legal documents. In addition, intimidation and humiliation by guards has further exacerbated Ms. Maxwell's feelings of insecurity due to officious power exerted upon her by guards.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "On Saturday, April 24, 2021, Leah Saffian, Esq. and I attended a pre-scheduled in-person legal conference with Ms. Maxwell in the MDC. The entire 2.5-hour conference was conducted under the constant watch of four to five guards, including a lieutenant, with a camera on a tripod focused on Ms. Maxwell and counsel while recording audio and video, and captured on surveillance cameras affixed within the visiting room. After counsel left the facility, Ms. Maxwell called me to report that her legal papers were confiscated.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Later that day, I received an email from Sophia Papapetru, MDC legal counsel, which stated:\nIt has been brought to my attention by the staff of MDC Brooklyn that Ms. Maxwell received paperwork that was not in her possession upon entering the legal visiting area. As you are aware, the policies set forth for MDC Brooklyn legal visits do not allow for passing of any material during a legal visit. Due to our policy and procedures, the additional documents that were provided to Ms. Maxwell were confiscated. Those materials were put in an envelope and will be returned to you tomorrow upon your arrival to the institution. Please note, that you may put these documents in the legal mailbox in the lobby of the east building.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "See Exhibit A.",
      "position": "bottom"
    },
    {
      "type": "stamp",
      "content": "USDC SDNY\nDOCUMENT\nELECTRONICALLY FILED\nDOC #: \nDATE FILED: 4/27/21",
      "position": "margin"
    },
    {
      "type": "printed",
      "content": "MDC legal counsel is hereby ORDERED to show cause by April 28, 2021 why an order directing the MDC to provide the information requested in this letter to the Defendant's counsel ought not issue. MDC legal counsel shall either docket it on ECF or email the letter to the Court so that the Court can docket it on ECF. Chambers will email a copy of this Order directly to legal counsel for the MDC.\nSO ORDERED.",
      "position": "footer"
    },
    {
      "type": "signature",
      "content": "Alison J. Nathan, U.S.D.J.",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Bobbi C. Sternheim",
      "Alison J. Nathan",
      "Ghislaine Maxwell",
      "Leah Saffian",
      "Sophia Papapetru"
    ],
    "organizations": [
      "LAW OFFICES OF BOBBI C. STERNHEIM",
      "United States District Judge",
      "United States Courthouse",
      "MDC Brooklyn"
    ],
    "locations": [
      "New York",
      "MDC Brooklyn",
      "United States"
    ],
    "dates": [
      "April 26, 2021",
      "April 24, 2021",
      "April 28, 2021",
      "4/27/21"
    ],
    "reference_numbers": [
      "S2 20 Cr. 330 (AJN)",
      "22433",
      "DOJ-OGR-00004027"
    ]
  },
  "additional_notes": "The document appears to be a letter from Bobbi C. Sternheim to Honorable Alison J. Nathan regarding an incident involving Ghislaine Maxwell. The letter is typed and contains a stamp indicating it was electronically filed with the USDC SDNY. The document is generally clear and legible."
}