{
  "document_metadata": {
    "page_number": "1 of 32",
    "document_number": "300",
    "date": "06/15/21",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 300 Filed 06/15/21 Page 1 of 32 LAW OFFICES OF BOBBI C. STERNHEIM 212-243-1100 * Main 917-306-6666 * Cell 888-587-4737 * Fax 33 West 19th Street - 4th Floor New York, New York 10011 bc@sternheimlaw.com June 15, 2021 Honorable Alison J. Nathan United States District Judge United States Courthouse 40 Foley Square New York, NY 10007 Re: United States v. Ghislaine Maxwell S2 20 Cr. 330 (AJN) Dear Judge Nathan: This letter is submitted in response to the government's letter of June 7, 2021, updating the Court concerning Ghislaine Maxwell's conditions of detention. This letter, like the ones before it, contains second- and third-hand information and presents a one-sided review, giving the Court and the public the false impression that Ms. Maxwell is detained under favorable and privileged conditions. Each time, the defense feels compelled to respond to give the Court and the public a complete and accurate picture of Ms. Maxwell's unacceptable conditions of confinement. This is not the purpose that these updates were designed to serve. Accordingly, the defense requests that any further updates be limited to changed circumstances. Counsel for Ms. Maxwell can personally attest to many problems that are not reported to the government, not conveyed to the Court, and not docketed for public review. The following is a sample of new and recurring problems: Last week, raw sewage permeated Ms. Maxwell's isolation cell, necessitating her removal to another cell. Vermin droppings fell from air vents. Guards now prevent Ms. Maxwell from removing legal documents from the videoconferencing room for review during the lunch hour. DOJ-OGR-00004744",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 300 Filed 06/15/21 Page 1 of 32",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "LAW OFFICES OF BOBBI C. STERNHEIM",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "212-243-1100 * Main 917-306-6666 * Cell 888-587-4737 * Fax 33 West 19th Street - 4th Floor New York, New York 10011 bc@sternheimlaw.com",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "June 15, 2021",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Honorable Alison J. Nathan United States District Judge United States Courthouse 40 Foley Square New York, NY 10007",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Re: United States v. Ghislaine Maxwell S2 20 Cr. 330 (AJN)",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Dear Judge Nathan: This letter is submitted in response to the government's letter of June 7, 2021, updating the Court concerning Ghislaine Maxwell's conditions of detention. This letter, like the ones before it, contains second- and third-hand information and presents a one-sided review, giving the Court and the public the false impression that Ms. Maxwell is detained under favorable and privileged conditions. Each time, the defense feels compelled to respond to give the Court and the public a complete and accurate picture of Ms. Maxwell's unacceptable conditions of confinement. This is not the purpose that these updates were designed to serve. Accordingly, the defense requests that any further updates be limited to changed circumstances. Counsel for Ms. Maxwell can personally attest to many problems that are not reported to the government, not conveyed to the Court, and not docketed for public review. The following is a sample of new and recurring problems: Last week, raw sewage permeated Ms. Maxwell's isolation cell, necessitating her removal to another cell. Vermin droppings fell from air vents. Guards now prevent Ms. Maxwell from removing legal documents from the videoconferencing room for review during the lunch hour.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00004744",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ghislaine Maxwell",
      "Bobbi C. Sternheim"
    ],
    "organizations": [
      "Law Offices of Bobbi C. Sternheim",
      "United States Courthouse"
    ],
    "locations": [
      "New York",
      "40 Foley Square"
    ],
    "dates": [
      "June 15, 2021",
      "June 7, 2021"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 300",
      "S2 20 Cr. 330 (AJN)",
      "DOJ-OGR-00004744"
    ]
  },
  "additional_notes": "The document appears to be a formal letter from the Law Offices of Bobbi C. Sternheim to Judge Alison J. Nathan regarding Ghislaine Maxwell's conditions of detention. The letter is typed and contains no handwritten text or stamps. The document is well-formatted and legible."
}