{
  "document_metadata": {
    "page_number": "1",
    "document_number": "321",
    "date": "08/19/21",
    "document_type": "Letter to Judge",
    "has_handwriting": true,
    "has_stamps": true
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 321 Filed 08/19/21 Page 1 of 3\nLAW OFFICES OF BOBBI C. STERNHEIM\n212-243-1100 • Main\n917-912-9698 • Cell\n888-587-4737 • Fax\n225 Broadway, Suite 715\nNew York, NY 10007\nbcsternheim@mac.com\nUSDC SDNY\nDOCUMENT\nELECTRONICALLY FILED\nDOC #: ___\nDATE FILED: 8/19/21\nAugust 18, 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 update the Court regarding MDC ongoing interference with attorney-client communication between Ghislaine Maxwell and her counsel.\nSince December 2019, video teleconferences (“VTCs”) between Ms. Maxwell and her counsel have been conducted via defense counsel's WebEx platform. There were no problems with VTCs with the exception of when the MDC placed the VTC monitor inside a box with a screen, which severely impacted Ms. Maxwell's ability to see counsel and documents shown to her. That issue, which arose on June 14, 2021, was resolved between defense counsel and the MDC.\nHowever, on August 6, 2021, MDC Legal sent counsel an email stating that starting Monday (August 9th) we could no longer use defense counsel's WebEx platform for the VTCs, and instead had to use any of four Zoom access codes provided by the MDC. When questioned why the platform was being changed from WebEx to Zoom, MDC Legal stated the VTC platform was changed due to complaints made by Ms. Maxwell. Upon information and belief, the complaints concerned visual evidence that someone on MDC's end of the WebEx connection, other than Ms. Maxwell, appeared on the screen as a VTC participant called “NER/BRO,” adjusted the volume during the VTC, and moved the viewing box used to view documents on the screen. During the past several weeks, interruption in Ms. Maxwell's VTC signal and bandwidth suggested that her connection was split, causing her VTC sessions to go in and out, and her screen often turned green and became blurry. No other participants experienced such disruption.\nWhen Ms. Maxwell raised these concerns to various staff members, no one seemed surprised. The fact that MDC immediately provided a “more secure” link (in their words) suggests there was some type of breach or interference with the attorney-client VTC which impinged upon confidentiality of privileged attorney-client communication and is placing an on-going chill on communication between Ms. Maxwell and her defense team.\nIt is my understanding that the new MDC Zoom platform does not preclude third parties who have the access information to the Zoom “Courtrooms” from interfering (inadvertently or intentionally) with Ms. Maxwell's privileged communication. That concern manifested itself on August 12th when\nSO ORDERED.\n8/19/21\nThe Government is hereby ORDERED to confer with BOP and MDC Legal and file a response to Defendant's letter on or before August 23, 2021.\nSO ORDERED.\nDOJ-OGR-00004998",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 321 Filed 08/19/21 Page 1 of 3",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "LAW OFFICES OF BOBBI C. STERNHEIM",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "212-243-1100 • Main\n917-912-9698 • Cell\n888-587-4737 • Fax",
      "position": "left margin"
    },
    {
      "type": "printed",
      "content": "225 Broadway, Suite 715\nNew York, NY 10007\nbcsternheim@mac.com",
      "position": "right margin"
    },
    {
      "type": "stamp",
      "content": "USDC SDNY\nDOCUMENT\nELECTRONICALLY FILED\nDOC #: ___\nDATE FILED: 8/19/21",
      "position": "left margin"
    },
    {
      "type": "printed",
      "content": "August 18, 2021",
      "position": "right margin"
    },
    {
      "type": "printed",
      "content": "Honorable Alison J. Nathan\nUnited States District Judge\nUnited States Courthouse\n40 Foley Square\nNew York, NY 10007",
      "position": "left margin"
    },
    {
      "type": "printed",
      "content": "Re: United States v. Ghislaine Maxwell\nS2 20 Cr. 330 (AJN)",
      "position": "left margin"
    },
    {
      "type": "printed",
      "content": "Dear Judge Nathan;",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "I write to update the Court regarding MDC ongoing interference with attorney-client communication between Ghislaine Maxwell and her counsel.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Since December 2019, video teleconferences (“VTCs”) between Ms. Maxwell and her counsel have been conducted via defense counsel's WebEx platform. There were no problems with VTCs with the exception of when the MDC placed the VTC monitor inside a box with a screen, which severely impacted Ms. Maxwell's ability to see counsel and documents shown to her. That issue, which arose on June 14, 2021, was resolved between defense counsel and the MDC.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "However, on August 6, 2021, MDC Legal sent counsel an email stating that starting Monday (August 9th) we could no longer use defense counsel's WebEx platform for the VTCs, and instead had to use any of four Zoom access codes provided by the MDC. When questioned why the platform was being changed from WebEx to Zoom, MDC Legal stated the VTC platform was changed due to complaints made by Ms. Maxwell. Upon information and belief, the complaints concerned visual evidence that someone on MDC's end of the WebEx connection, other than Ms. Maxwell, appeared on the screen as a VTC participant called “NER/BRO,” adjusted the volume during the VTC, and moved the viewing box used to view documents on the screen. During the past several weeks, interruption in Ms. Maxwell's VTC signal and bandwidth suggested that her connection was split, causing her VTC sessions to go in and out, and her screen often turned green and became blurry. No other participants experienced such disruption.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "When Ms. Maxwell raised these concerns to various staff members, no one seemed surprised. The fact that MDC immediately provided a “more secure” link (in their words) suggests there was some type of breach or interference with the attorney-client VTC which impinged upon confidentiality of privileged attorney-client communication and is placing an on-going chill on communication between Ms. Maxwell and her defense team.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "It is my understanding that the new MDC Zoom platform does not preclude third parties who have the access information to the Zoom “Courtrooms” from interfering (inadvertently or intentionally) with Ms. Maxwell's privileged communication. That concern manifested itself on August 12th when",
      "position": "body"
    },
    {
      "type": "handwritten",
      "content": "SO ORDERED.\n8/19/21",
      "position": "signature"
    },
    {
      "type": "printed",
      "content": "The Government is hereby ORDERED to confer with BOP and MDC Legal and file a response to Defendant's letter on or before August 23, 2021.\nSO ORDERED.",
      "position": "right margin"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00004998",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ghislaine Maxwell",
      "Bobbi C. Sternheim"
    ],
    "organizations": [
      "Law Offices of Bobbi C. Sternheim",
      "United States District Court",
      "MDC",
      "BOP"
    ],
    "locations": [
      "New York",
      "NY",
      "United States"
    ],
    "dates": [
      "August 18, 2021",
      "December 2019",
      "June 14, 2021",
      "August 6, 2021",
      "August 9, 2021",
      "August 12, 2021",
      "August 23, 2021",
      "08/19/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "Document 321",
      "S2 20 Cr. 330 (AJN)",
      "DOJ-OGR-00004998"
    ]
  },
  "additional_notes": "The document appears to be a letter to Judge Alison J. Nathan regarding issues with attorney-client communication between Ghislaine Maxwell and her counsel due to interference from the MDC. The letter is from Bobbi C. Sternheim, Maxwell's lawyer. The document includes a stamp from the USDC SDNY and a handwritten signature from Judge Nathan."
}