{
  "document_metadata": {
    "page_number": "24 of 77",
    "document_number": "663",
    "date": "06/15/22",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 663 Filed 06/15/22 Page 24 of 77\n\nthroughout the night. When the bright lights were turned off in her cell, bright lights remained on directly outside her cell; and the flashlight checks continued, a regime completely inappropriate for a non-suicidal inmate. This unjustified sleep deprivation - which continued throughout trial and afterward - affected her general physical condition as well as her psychological well-being. This practice does not exist in general population.\n\nDespite never being in contact with any other inmate, under continuous surveillance by prison guards and cameras, and escorted to and from any isolated location, she was subjected to an excessive number of physical searches on a daily basis: pat-down searches, strip searches, body-cavity searches. She was unnecessarily exposed to radiation from body scanners; and was fortunate not to contract COVID when guards, who were not required to take COVID tests, looked and searched inside her mouth. Her cell was searched multiple times daily. The searches were redundant, unreasonable, unnecessary, and abusive beyond any legitimate penological purpose, especially where Ms. Maxwell had no opportunity to acquire contraband. See Hodges v. Stanley, 712 F.2d 34, 35-36 (2d Cir. 1983). At times, searches were conducted in inappropriate ways and were especially painful humiliating and intimidating, as when her breasts and genitalia were touched in a rough and reckless manner. Reports by Ms. Maxwell and counsel concerning sexually inappropriate searches by corrections officers went nowhere.\n\nIt is clearly established that excessive searches are unnecessary and unreasonable when a prisoner is isolated from other inmates and never out of range of the camera or a guard. Ms. Maxwell was searched every time she was removed from or returned to her isolation cell, even when she had no conceivable opportunity (let alone no intention) to obtain contraband. Clearly, the search policy is one that was not applied consistently. Having been in general population for the past two months, Ms. Maxwell has only been searched after contact visits with counsel.\n\n23\nDOJ-OGR-00010470",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 663 Filed 06/15/22 Page 24 of 77",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "throughout the night. When the bright lights were turned off in her cell, bright lights remained on directly outside her cell; and the flashlight checks continued, a regime completely inappropriate for a non-suicidal inmate. This unjustified sleep deprivation - which continued throughout trial and afterward - affected her general physical condition as well as her psychological well-being. This practice does not exist in general population.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Despite never being in contact with any other inmate, under continuous surveillance by prison guards and cameras, and escorted to and from any isolated location, she was subjected to an excessive number of physical searches on a daily basis: pat-down searches, strip searches, body-cavity searches. She was unnecessarily exposed to radiation from body scanners; and was fortunate not to contract COVID when guards, who were not required to take COVID tests, looked and searched inside her mouth. Her cell was searched multiple times daily. The searches were redundant, unreasonable, unnecessary, and abusive beyond any legitimate penological purpose, especially where Ms. Maxwell had no opportunity to acquire contraband. See Hodges v. Stanley, 712 F.2d 34, 35-36 (2d Cir. 1983). At times, searches were conducted in inappropriate ways and were especially painful humiliating and intimidating, as when her breasts and genitalia were touched in a rough and reckless manner. Reports by Ms. Maxwell and counsel concerning sexually inappropriate searches by corrections officers went nowhere.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "It is clearly established that excessive searches are unnecessary and unreasonable when a prisoner is isolated from other inmates and never out of range of the camera or a guard. Ms. Maxwell was searched every time she was removed from or returned to her isolation cell, even when she had no conceivable opportunity (let alone no intention) to obtain contraband. Clearly, the search policy is one that was not applied consistently. Having been in general population for the past two months, Ms. Maxwell has only been searched after contact visits with counsel.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "23",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00010470",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Maxwell"
    ],
    "organizations": [],
    "locations": [],
    "dates": [
      "06/15/22"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 663",
      "712 F.2d 34",
      "DOJ-OGR-00010470"
    ]
  },
  "additional_notes": "The document appears to be a court filing discussing the treatment of Ms. Maxwell while in prison. The text is printed and there are no visible stamps or handwritten notes. The document is likely a legal brief or memorandum."
}