{
  "document_metadata": {
    "page_number": "2",
    "document_number": "78",
    "date": "12/01/20",
    "document_type": "Court Document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 78 Filed 12/01/20 Page 2 of 2\n\nPage 2\n\nsearching (e.g., weekly body scan, 15-minute interval flashlight checks at night, and open-mouth inspection) despite being surveilled 24/7 by a dedicated three-guard security detail and two cameras; and the reason she is not being moved to the day room, which we understood was the original plan (and would reduce searching). Receipt of the letter was acknowledged, but to date there has been no response and little, if any, redress to the most serious conditions. Upon information and belief, decisions concerning Ms. Maxwell's specialized detention are made by Warden Tellez, or from others outside the MDC. A report from the MDC Legal Department would provide second-hand information. Accordingly, Warden Tellez should be directed to provide a first-hand accounting to the Court and counsel why Ms. Maxwell is being detained under such individualized conditions.\n\nYour consideration is greatly appreciated.\n\nRespectfully submitted,\n\nAUDREY STRAUSS\nActing United States Attorney\n\nBy: s/\nMaurene Comey / Alison Moe / Lara Pomerantz\nAssistant United States Attorneys\nSouthern District of New York\nTel: (212) 637-2324\n\nCc: All Counsel of Record (By ECF)",
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      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 78 Filed 12/01/20 Page 2 of 2",
      "position": "header"
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    {
      "type": "printed",
      "content": "Page 2",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "searching (e.g., weekly body scan, 15-minute interval flashlight checks at night, and open-mouth inspection) despite being surveilled 24/7 by a dedicated three-guard security detail and two cameras; and the reason she is not being moved to the day room, which we understood was the original plan (and would reduce searching). Receipt of the letter was acknowledged, but to date there has been no response and little, if any, redress to the most serious conditions. Upon information and belief, decisions concerning Ms. Maxwell's specialized detention are made by Warden Tellez, or from others outside the MDC. A report from the MDC Legal Department would provide second-hand information. Accordingly, Warden Tellez should be directed to provide a first-hand accounting to the Court and counsel why Ms. Maxwell is being detained under such individualized conditions.",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "Your consideration is greatly appreciated.",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "Respectfully submitted,",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "AUDREY STRAUSS\nActing United States Attorney",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "By: s/\nMaurene Comey / Alison Moe / Lara Pomerantz\nAssistant United States Attorneys\nSouthern District of New York\nTel: (212) 637-2324",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "Cc: All Counsel of Record (By ECF)",
      "position": "footer"
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  ],
  "entities": {
    "people": [
      "Ms. Maxwell",
      "Warden Tellez",
      "AUDREY STRAUSS",
      "Maurene Comey",
      "Alison Moe",
      "Lara Pomerantz"
    ],
    "organizations": [
      "MDC Legal Department",
      "United States Attorney",
      "Southern District of New York"
    ],
    "locations": [
      "New York"
    ],
    "dates": [
      "12/01/20"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "78",
      "(212) 637-2324"
    ]
  },
  "additional_notes": "The document appears to be a court filing with a formal tone and proper formatting. There are no visible redactions or damage."
}