{
  "document_metadata": {
    "page_number": "24",
    "document_number": "20-CR-330(AJN)",
    "date": null,
    "document_type": "Court Document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 206-1 Filed 08/28/20 Page 24 of 95\n\nAccording to , the security guard on duty that day had seen helicopters flying over the house, which he assumed to be the press. (Id.). When the guard saw the FBI agents walking up the driveway to the house, he again assumed that they were members of the press. (Id.). Accordingly, he radioed Ms. Maxwell to alert her that the press was on the grounds and approaching the house. (Id.). In accordance with the procedure that Ms. Maxwell's security personnel had put in place for such an event, Ms. Maxwell moved away from the windows and into a safe room inside the house. (Id.). Ms. Maxwell was not trying to avoid arrest; she was simply following the established security protocols to protect herself from what had been informed was an ambush by the press.\n\nRegarding the cellphone wrapped in tin foil, we explained to the Court at the initial bail hearing that Ms. Maxwell took this step to prevent the press from accessing her phone after the Second Circuit inadvertently unsealed certain court records with the phone number unredacted. (Tr. 55-56). Having now reviewed the discovery produced by the government, it is clear that Ms. Maxwell was not at all the “master spy” the government makes her out to be and was not wrapping the phone in order to evade detection by law enforcement.\n\nFirst, the cellphone in question was subscribed in the name of “Terramar Project, Inc.,” which is easily identifiable through a simple Google search as Ms. Maxwell's charity.\n\nSecond, Ms. Maxwell used the phone to make calls as late as May 2020, just before her arrest. She would never have used the phone if she had been concerned that the authorities were using it to track her. Third, Ms. Maxwell had another phone subscribed in the name of “G Max” that she was using as her primary phone, which was not covered. It would make no sense for her to try to wrap one phone in tin foil to avoid detection and not the other.\n\n24\nDOJ-OGR-00001126",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 206-1 Filed 08/28/20 Page 24 of 95",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "According to , the security guard on duty that day had seen helicopters flying over the house, which he assumed to be the press. (Id.). When the guard saw the FBI agents walking up the driveway to the house, he again assumed that they were members of the press. (Id.). Accordingly, he radioed Ms. Maxwell to alert her that the press was on the grounds and approaching the house. (Id.). In accordance with the procedure that Ms. Maxwell's security personnel had put in place for such an event, Ms. Maxwell moved away from the windows and into a safe room inside the house. (Id.). Ms. Maxwell was not trying to avoid arrest; she was simply following the established security protocols to protect herself from what had been informed was an ambush by the press.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Regarding the cellphone wrapped in tin foil, we explained to the Court at the initial bail hearing that Ms. Maxwell took this step to prevent the press from accessing her phone after the Second Circuit inadvertently unsealed certain court records with the phone number unredacted. (Tr. 55-56). Having now reviewed the discovery produced by the government, it is clear that Ms. Maxwell was not at all the “master spy” the government makes her out to be and was not wrapping the phone in order to evade detection by law enforcement.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "First, the cellphone in question was subscribed in the name of “Terramar Project, Inc.,” which is easily identifiable through a simple Google search as Ms. Maxwell's charity.\n\nSecond, Ms. Maxwell used the phone to make calls as late as May 2020, just before her arrest. She would never have used the phone if she had been concerned that the authorities were using it to track her. Third, Ms. Maxwell had another phone subscribed in the name of “G Max” that she was using as her primary phone, which was not covered. It would make no sense for her to try to wrap one phone in tin foil to avoid detection and not the other.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "24",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00001126",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Ms. Maxwell"
    ],
    "organizations": [
      "FBI",
      "Second Circuit",
      "Terramar Project, Inc."
    ],
    "locations": [],
    "dates": [
      "May 2020",
      "08/28/20"
    ],
    "reference_numbers": [
      "20-CR-330(AJN)",
      "206-1",
      "DOJ-OGR-00001126"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Ms. Maxwell. The text is printed and there are no visible stamps or handwritten notes. The document is page 24 of a 95-page document."
}