{
  "document_metadata": {
    "page_number": "8",
    "document_number": "22433",
    "date": "April 26, 2021",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case#: 2020-cr-00083-BAEN Document#: 22433 Filed#: 04/26/21 Page#: 8 of 9\nLAW OFFICES OF BOBBI C. STERNHEIM\n212-243-1100 * Main 33 West 19th Street - 4th Floor\n917-306-6666 * Cell New York, New York 10011\n888-587-4737 * Fax bc@sternheimlaw.com\nApril 26, 2021\nVIA EMAIL AND U.S. MAIL\nSophia Papapetru, Esq.\nLegal Counsel\nMetropolitan Detention Center\n80 29th Street\nBrooklyn, NY 11232\nspapapetru@bop.gov\nNOTICE AND DEMAND TO PRESERVE ITEMS OF EVIDENCE\nRe: Ghislaine Maxwell 02879-509\nDear Ms. Papapetru:\nAs counsel for Ghislaine Maxwell, 02879-054, I am notifying you, as legal counsel for the Metropolitan Detention Center, of the MDC's obligation to preserve documents and evidence related to (i) allegations made against Ms. Maxwell and her counsel regarding legal paperwork allegedly passed to Ms. Maxwell during an attorney-client conference on April 24, 2021 and (ii) the confiscation and review of Ms. Maxwell's documents by MDC staff.\nAs stated in my April 24th email, material relevant to this dispute includes, but is not limited to:\n- Any images, data files, or video recordings of the legal conference as captured on the hand-held camera focused on Ms. Maxwell and counsel during the entirety of the legal conference.\n- Any images, data files, or video recordings of the legal conference as captured on surveillance cameras focused on Ms. Maxwell and counsel during the entirety of the legal conference.\n- The full names of all guards, including the lieutenant, present in the visiting room during the legal conference.\n- Any written or recorded communications, whether stored in electronic, digital or paper format, obtained in connection with the incident identified above.\n- A list of all documents claimed to be in Ms. Maxwell's possession upon entering the visiting room. This request includes copies of any such documents or notes regarding same.\nEXHIBIT C\nDOJ-OGR-00004034",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case#: 2020-cr-00083-BAEN Document#: 22433 Filed#: 04/26/21 Page#: 8 of 9",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "LAW OFFICES OF BOBBI C. STERNHEIM",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "212-243-1100 * Main 33 West 19th Street - 4th Floor\n917-306-6666 * Cell New York, New York 10011\n888-587-4737 * Fax bc@sternheimlaw.com",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "April 26, 2021",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "VIA EMAIL AND U.S. MAIL\nSophia Papapetru, Esq.\nLegal Counsel\nMetropolitan Detention Center\n80 29th Street\nBrooklyn, NY 11232\nspapapetru@bop.gov",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "NOTICE AND DEMAND TO PRESERVE ITEMS OF EVIDENCE",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Re: Ghislaine Maxwell 02879-509",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Dear Ms. Papapetru:",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "As counsel for Ghislaine Maxwell, 02879-054, I am notifying you, as legal counsel for the Metropolitan Detention Center, of the MDC's obligation to preserve documents and evidence related to (i) allegations made against Ms. Maxwell and her counsel regarding legal paperwork allegedly passed to Ms. Maxwell during an attorney-client conference on April 24, 2021 and (ii) the confiscation and review of Ms. Maxwell's documents by MDC staff.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "As stated in my April 24th email, material relevant to this dispute includes, but is not limited to:",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "- Any images, data files, or video recordings of the legal conference as captured on the hand-held camera focused on Ms. Maxwell and counsel during the entirety of the legal conference.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "- Any images, data files, or video recordings of the legal conference as captured on surveillance cameras focused on Ms. Maxwell and counsel during the entirety of the legal conference.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "- The full names of all guards, including the lieutenant, present in the visiting room during the legal conference.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "- Any written or recorded communications, whether stored in electronic, digital or paper format, obtained in connection with the incident identified above.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "- A list of all documents claimed to be in Ms. Maxwell's possession upon entering the visiting room. This request includes copies of any such documents or notes regarding same.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "EXHIBIT C",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00004034",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Bobbi C. Sternheim",
      "Sophia Papapetru",
      "Ghislaine Maxwell"
    ],
    "organizations": [
      "LAW OFFICES OF BOBBI C. STERNHEIM",
      "Metropolitan Detention Center"
    ],
    "locations": [
      "New York",
      "Brooklyn"
    ],
    "dates": [
      "April 26, 2021",
      "April 24, 2021"
    ],
    "reference_numbers": [
      "2020-cr-00083-BAEN",
      "22433",
      "02879-509",
      "02879-054",
      "DOJ-OGR-00004034"
    ]
  },
  "additional_notes": "The document appears to be a formal letter from the Law Offices of Bobbi C. Sternheim to Sophia Papapetru, Esq. at the Metropolitan Detention Center. The letter is a notice and demand to preserve items of evidence related to Ghislaine Maxwell. The document is well-formatted and legible."
}