{
  "document_metadata": {
    "page_number": "1",
    "document_number": "327",
    "date": "08/24/21",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 327 Filed 08/24/21 Page 1 of 1\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\nAugust 24, 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:\nThe government cannot resist the opportunity to gratuitously cast Ghislaine Maxwell in a negative light while it defends the Metropolitan Detention Center at all costs, regardless of the facts. [Dkt. 326]. The government accuses Ms. Maxwell of using a cart to barricade the door to the VTC room. The cart was never used to barricade. The government has chosen to make this an issue - when it never was - to justify the restriction placed on the amount of legal materials Ms. Maxwell can bring into the VTC room on any given day.\nThe government mischaracterizes facts to which it does not have first-hand knowledge. Ms. Maxwell continues to use the cart daily to bring legal material into the VTC room and to remove those documents at the end of the VTC session. Most of her legal papers are kept in a separate room. She is only allowed to bring a certain portion of documents to any given VTC session and is not allowed to leave the VTC room to collect additional documents that may be needed for review and discussion with counsel. The amount of legal material Ms. Maxwell can access depends upon rules that fluctuate with each team rotated into the MDC every two weeks to guard her.\nThis limitation impacts the productivity of VTC and in-person legal conferences and compromises Ms. Maxwell's ability to prepare for trial.\nVery truly yours,\n/s/\nBOBBI C. STERNHEIM\ncc: All counsel\nDOJ-OGR-00005014",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 327 Filed 08/24/21 Page 1 of 1",
      "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\n225 Broadway, Suite 715\nNew York, NY 10007\nbcsternheim@mac.com",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "August 24, 2021",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Honorable Alison J. Nathan\nUnited States District Judge\nUnited States Courthouse\n40 Foley Square\nNew York, NY 10007",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Re: United States v. Ghislaine Maxwell\nS2 20 Cr. 330 (AJN)",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Dear Judge Nathan:",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The government cannot resist the opportunity to gratuitously cast Ghislaine Maxwell in a negative light while it defends the Metropolitan Detention Center at all costs, regardless of the facts. [Dkt. 326]. The government accuses Ms. Maxwell of using a cart to barricade the door to the VTC room. The cart was never used to barricade. The government has chosen to make this an issue - when it never was - to justify the restriction placed on the amount of legal materials Ms. Maxwell can bring into the VTC room on any given day.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The government mischaracterizes facts to which it does not have first-hand knowledge. Ms. Maxwell continues to use the cart daily to bring legal material into the VTC room and to remove those documents at the end of the VTC session. Most of her legal papers are kept in a separate room. She is only allowed to bring a certain portion of documents to any given VTC session and is not allowed to leave the VTC room to collect additional documents that may be needed for review and discussion with counsel. The amount of legal material Ms. Maxwell can access depends upon rules that fluctuate with each team rotated into the MDC every two weeks to guard her.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "This limitation impacts the productivity of VTC and in-person legal conferences and compromises Ms. Maxwell's ability to prepare for trial.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Very truly yours,",
      "position": "bottom"
    },
    {
      "type": "signature",
      "content": "/s/",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "BOBBI C. STERNHEIM",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "cc: All counsel",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00005014",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ghislaine Maxwell",
      "Bobbi C. Sternheim"
    ],
    "organizations": [
      "LAW OFFICES OF BOBBI C. STERNHEIM",
      "United States District Judge",
      "United States Courthouse",
      "Metropolitan Detention Center"
    ],
    "locations": [
      "New York",
      "NY",
      "Broadway",
      "Foley Square"
    ],
    "dates": [
      "August 24, 2021",
      "08/24/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "Document 327",
      "S2 20 Cr. 330 (AJN)",
      "Dkt. 326",
      "DOJ-OGR-00005014"
    ]
  },
  "additional_notes": "The document appears to be a formal letter from Bobbi C. Sternheim to Honorable Alison J. Nathan regarding the case United States v. Ghislaine Maxwell. The letter is typed on the letterhead of Law Offices of Bobbi C. Sternheim and includes contact information. The content discusses issues related to Ghislaine Maxwell's access to legal materials while in detention."
}