{
  "document_metadata": {
    "page_number": "1",
    "document_number": "352",
    "date": "10/15/21",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 352 Filed 10/15/21 Page 1 of 2\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\nOctober 15, 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\n20 Cr. 330 (AJN)\nDear Judge Nathan:\nThe Government's letter concerning delayed delivery of Ghislaine Maxwell's legal mail (Dkt. 350) merely parrots the MDC's standard excuses, adding a BOP version of \"my dog ate my homework.\"\nThe response is woefully inadequate and makes light of the MDC's encroachment on Ms. Maxwell's ability to prepare for trial and confer with counsel. It does not explain MDC's failure to respond to counsel's requests. It utterly fails to address the issue regarding the extremely late delivery of legal mail placed by counsel in the legal mailbox on October 2 but not discovered until October 7; nor the presence of a sticker with a bar code of the type issued by the U.S. Post Office and unfamiliar to the Warden and Unit Manager.\nIf it is not too burdensome for the MDC to rotate in extra officers from BOP facilities nationwide to overmanage and monitor Ms. Maxwell's every move and every second she confers with counsel in the visiting room, the MDC should be able to deliver legal mail in a timely fashion. It is not surprising that the Government asserts that this case and the circumstances do not merit special expedited delivery.\nIt dug its heels in when making it clear that it would not go out of its way to have the hard drive hand delivered to the MDC to ensure that Ms. Maxwell would receive it expeditiously, an accommodation it had previously made.\nDOJ-OGR-00005241",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 352 Filed 10/15/21 Page 1 of 2",
      "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": "October 15, 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\n20 Cr. 330 (AJN)",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Dear Judge Nathan:",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The Government's letter concerning delayed delivery of Ghislaine Maxwell's legal mail (Dkt. 350) merely parrots the MDC's standard excuses, adding a BOP version of \"my dog ate my homework.\"\nThe response is woefully inadequate and makes light of the MDC's encroachment on Ms. Maxwell's ability to prepare for trial and confer with counsel. It does not explain MDC's failure to respond to counsel's requests. It utterly fails to address the issue regarding the extremely late delivery of legal mail placed by counsel in the legal mailbox on October 2 but not discovered until October 7; nor the presence of a sticker with a bar code of the type issued by the U.S. Post Office and unfamiliar to the Warden and Unit Manager.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "If it is not too burdensome for the MDC to rotate in extra officers from BOP facilities nationwide to overmanage and monitor Ms. Maxwell's every move and every second she confers with counsel in the visiting room, the MDC should be able to deliver legal mail in a timely fashion. It is not surprising that the Government asserts that this case and the circumstances do not merit special expedited delivery.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "It dug its heels in when making it clear that it would not go out of its way to have the hard drive hand delivered to the MDC to ensure that Ms. Maxwell would receive it expeditiously, an accommodation it had previously made.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00005241",
      "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",
      "U.S. Post Office",
      "DOJ"
    ],
    "locations": [
      "New York",
      "Broadway"
    ],
    "dates": [
      "October 15, 2021",
      "October 2",
      "October 7",
      "10/15/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 352",
      "20 Cr. 330 (AJN)",
      "Dkt. 350",
      "DOJ-OGR-00005241"
    ]
  },
  "additional_notes": "The document appears to be a formal letter from Bobbi C. Sternheim to Judge Alison J. Nathan regarding the case United States v. Ghislaine Maxwell. The letter discusses issues related to the delivery of Ghislaine Maxwell's legal mail while in custody."
}