{
  "document_metadata": {
    "page_number": "3 of 3",
    "document_number": "319",
    "date": "08/18/21",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "of the quantity of legal materials she is permitted to use during working session severely hamper her ability to prepare her defense for trial.\n\nOn August 17th, the third day without VTC for Ms. Maxwell and counsel, I told MDC Legal that the defense has reason to be concerned that VTCs between Ms. Maxwell and counsel may have been tape recorded by the MDC, a concern that accords with our belief that there has been inference with the VTCs on the MDC's end. Notably, when Ms. Maxwell reported to MDC staff her concern that VTCs were being taped, she received no response. Likewise, counsel have received no response from MDC Legal regarding this concern.\n\nAs of the writing of this letter, there has been no resumption of VTCs, and the MDC has provided no information.\n\nAny interference by the MDC, BOP, or other government entity with confidential privileged communication between Ms. Maxwell and her counsel is a serious breach of BOP policy, professional ethics, ABA standards and a violation of Ms. Maxwell's constitutional rights. Further, it is seriously impacting her ability to prepare for trial, a situation already compromised by the conditions of her detention.\n\nBased on the foregoing, I request that the Court direct MDC Legal to show cause\n- Why the VTC platform has been changed.\n- Why resumption of VTCs has been delayed.\n- Why VTCs cannot be reinstated on defense counsel's WebEx platform.\n\nFurther, it is requested that MDC legal provide a sworn statement regarding whether any VTCs between Ms. Maxwell and counsel have been interfered with, listened to, and/or recorded.\n\nYour consideration is greatly appreciated.\n\nVery truly yours,\n\n/s/\nBOBBI C. STERNHEIM\n\ncc: All counsel",
  "text_blocks": [
    {
      "type": "printed",
      "content": "of the quantity of legal materials she is permitted to use during working session severely hamper her ability to prepare her defense for trial.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "On August 17th, the third day without VTC for Ms. Maxwell and counsel, I told MDC Legal that the defense has reason to be concerned that VTCs between Ms. Maxwell and counsel may have been tape recorded by the MDC, a concern that accords with our belief that there has been inference with the VTCs on the MDC's end. Notably, when Ms. Maxwell reported to MDC staff her concern that VTCs were being taped, she received no response. Likewise, counsel have received no response from MDC Legal regarding this concern.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "As of the writing of this letter, there has been no resumption of VTCs, and the MDC has provided no information.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Any interference by the MDC, BOP, or other government entity with confidential privileged communication between Ms. Maxwell and her counsel is a serious breach of BOP policy, professional ethics, ABA standards and a violation of Ms. Maxwell's constitutional rights. Further, it is seriously impacting her ability to prepare for trial, a situation already compromised by the conditions of her detention.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Based on the foregoing, I request that the Court direct MDC Legal to show cause\n- Why the VTC platform has been changed.\n- Why resumption of VTCs has been delayed.\n- Why VTCs cannot be reinstated on defense counsel's WebEx platform.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Further, it is requested that MDC legal provide a sworn statement regarding whether any VTCs between Ms. Maxwell and counsel have been interfered with, listened to, and/or recorded.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Your consideration is greatly appreciated.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Very truly yours,",
      "position": "bottom"
    },
    {
      "type": "signature",
      "content": "/s/ BOBBI C. STERNHEIM",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "cc: All counsel",
      "position": "bottom"
    }
  ],
  "entities": {
    "people": [
      "Ms. Maxwell",
      "BOBBI C. STERNHEIM"
    ],
    "organizations": [
      "MDC",
      "BOP",
      "MDC Legal",
      "ABA",
      "LAW OFFICES OF BOBBI C. STERNHEIM"
    ],
    "locations": [],
    "dates": [
      "August 17th",
      "08/18/21"
    ],
    "reference_numbers": [
      "Case 1:20-cr-00330-PAE",
      "Document 319",
      "DOJ-OGR-00004993"
    ]
  },
  "additional_notes": "The document appears to be a formal letter from Bobbi C. Sternheim to an unspecified recipient regarding issues with VTCs between Ms. Maxwell and her counsel. The letter is well-formatted and free of significant damage or redactions."
}