{
  "document_metadata": {
    "page_number": "16",
    "document_number": "20-1",
    "date": "04/01/2021",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 21-770, Document 20-1, 04/01/2021, 3068530, Page16 of 31\n\nthe real ability to meet with your lawyers face-to-face while being kept up all night and being given inedible food makes it virtually impossible, and violates Ms. Maxwell's constitutional rights.\n\nSection 3142(i) makes clear that defendants must have the ability to consult with counsel and effectively prepare for their defense. If this is not possible in custody, release is required. United States v. Chandler, 1:19-CR-867 (PAC), 2020 WL 1528120, at *2 (S.D.N.Y. Mar. 31, 2020) (extraordinary burdens imposed by the coronavirus pandemic, in conjunction with detainee's right to prepare for his defense, constituted compelling reason to order temporary release from Metropolitan Correction Center). The COVID epidemic is still raging and conditions at MDC are unsafe.6\n\nMs. Maxwell's continued detention would be wrong at any point in this nation's history, even when stealing a loaf of bread was a felony. It is especially unwarranted now. \"The hazards of a pandemic are immediate and direct, and still the rights of criminal defendants who are\n\n6 Just for example, the air is not properly filtered in the small, enclosed attorney visit rooms at MDC and has been described as \"a death trap\" for lawyers and inmates. Ex.K, n.8. Even though the prison is technically open for legal visits, lawyers are understandably not willing to walk into a viral petri dish.\n\n14\nDOJ-OGR-00000926",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 21-770, Document 20-1, 04/01/2021, 3068530, Page16 of 31",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "the real ability to meet with your lawyers face-to-face while being kept up all night and being given inedible food makes it virtually impossible, and violates Ms. Maxwell's constitutional rights.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Section 3142(i) makes clear that defendants must have the ability to consult with counsel and effectively prepare for their defense. If this is not possible in custody, release is required. United States v. Chandler, 1:19-CR-867 (PAC), 2020 WL 1528120, at *2 (S.D.N.Y. Mar. 31, 2020) (extraordinary burdens imposed by the coronavirus pandemic, in conjunction with detainee's right to prepare for his defense, constituted compelling reason to order temporary release from Metropolitan Correction Center). The COVID epidemic is still raging and conditions at MDC are unsafe.6",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Ms. Maxwell's continued detention would be wrong at any point in this nation's history, even when stealing a loaf of bread was a felony. It is especially unwarranted now. \"The hazards of a pandemic are immediate and direct, and still the rights of criminal defendants who are",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "6 Just for example, the air is not properly filtered in the small, enclosed attorney visit rooms at MDC and has been described as \"a death trap\" for lawyers and inmates. Ex.K, n.8. Even though the prison is technically open for legal visits, lawyers are understandably not willing to walk into a viral petri dish.",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "14",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00000926",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Ms. Maxwell"
    ],
    "organizations": [
      "Metropolitan Correction Center",
      "MDC"
    ],
    "locations": [
      "S.D.N.Y."
    ],
    "dates": [
      "04/01/2021",
      "Mar. 31, 2020"
    ],
    "reference_numbers": [
      "Case 21-770",
      "Document 20-1",
      "3068530",
      "1:19-CR-867 (PAC)",
      "2020 WL 1528120",
      "DOJ-OGR-00000926"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Ms. Maxwell, discussing her detention conditions and the impact of the COVID-19 pandemic. The text is printed, with no handwritten content or stamps visible."
}