{
  "document_metadata": {
    "page_number": "7",
    "document_number": "21-cr-00380",
    "date": "07/07/20",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00380-AJN Document 18 Filed 07/07/20 Page 7 of 26\n\nfive staff had tested positive; by June 30, 2020, those numbers had risen to 14 and 41, respectively.4 The increased spread among prisons means that the COVID-19 risks that were present in the Stephens case four months ago are far more serious for Ms. Maxwell now and mandate her release.\n\nImpact of COVID-19 on the Ability to Prepare the Defense. The Stephens opinion provides yet another independent basis that, we submit, requires Ms. Maxwell's release: if she is detained, her ability to meet with her attorneys and prepare for her defense will be significantly impaired and she will not be able to meaningfully participate in the preparation of her defense.\n\nIn Stephens, the Court found that this factor required the defendant's release under 18 U.S.C. § 3142(i), which provides for temporary release based on a determination that such release is \"necessary for preparation of the person's defense.\" Stephens, 2020 WL 1295155 at *3. The Court noted that the spread of COVID-19 had compelled the BOP to suspend all in-person visits, including legal visits, except as allowed on a case-by-case basis. Id. at *3. That suspension persists to this day.5 In a case such as this, which will require assessing evidence relating to events that occurred approximately twenty-five years ago, including documents and personal recollections, numerous in-person meetings between counsel and Ms. Maxwell will be critical to the preparation of the defense. The recent resurgence of the pandemic calls into question whether these meetings will ever be able to happen in advance of her trial. As in\n\n4 See April 3, 2020 Report from the BOP regarding the Metropolitan Detention Center and Metropolitan Correctional Center (\"MDC and MCC Report\"), available at https://img.nyed.uscourts.gov/files/reports/bop/20200403_BOP_Report.pdf; and June 30, 2020 MDC and MCC Report, available at https://www.nyed.uscourts.gov/pub/bop/MDC_MCC_20200630_071147.pdf.\n\n5 See BOP COVID-19 Modified Operations Plan, available at https://www.bop.gov/coronavirus/covid19_status.jsp.\n\n7\n\nDOJ-OGR-00000967",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00380-AJN Document 18 Filed 07/07/20 Page 7 of 26",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "five staff had tested positive; by June 30, 2020, those numbers had risen to 14 and 41, respectively.4 The increased spread among prisons means that the COVID-19 risks that were present in the Stephens case four months ago are far more serious for Ms. Maxwell now and mandate her release.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Impact of COVID-19 on the Ability to Prepare the Defense. The Stephens opinion provides yet another independent basis that, we submit, requires Ms. Maxwell's release: if she is detained, her ability to meet with her attorneys and prepare for her defense will be significantly impaired and she will not be able to meaningfully participate in the preparation of her defense.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "In Stephens, the Court found that this factor required the defendant's release under 18 U.S.C. § 3142(i), which provides for temporary release based on a determination that such release is \"necessary for preparation of the person's defense.\" Stephens, 2020 WL 1295155 at *3. The Court noted that the spread of COVID-19 had compelled the BOP to suspend all in-person visits, including legal visits, except as allowed on a case-by-case basis. Id. at *3. That suspension persists to this day.5 In a case such as this, which will require assessing evidence relating to events that occurred approximately twenty-five years ago, including documents and personal recollections, numerous in-person meetings between counsel and Ms. Maxwell will be critical to the preparation of the defense. The recent resurgence of the pandemic calls into question whether these meetings will ever be able to happen in advance of her trial. As in",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "4 See April 3, 2020 Report from the BOP regarding the Metropolitan Detention Center and Metropolitan Correctional Center (\"MDC and MCC Report\"), available at https://img.nyed.uscourts.gov/files/reports/bop/20200403_BOP_Report.pdf; and June 30, 2020 MDC and MCC Report, available at https://www.nyed.uscourts.gov/pub/bop/MDC_MCC_20200630_071147.pdf.",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "5 See BOP COVID-19 Modified Operations Plan, available at https://www.bop.gov/coronavirus/covid19_status.jsp.",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "7",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00000967",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Ms. Maxwell"
    ],
    "organizations": [
      "BOP",
      "MDC",
      "MCC"
    ],
    "locations": [],
    "dates": [
      "June 30, 2020",
      "April 3, 2020"
    ],
    "reference_numbers": [
      "21-cr-00380",
      "DOJ-OGR-00000967"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Ms. Maxwell, discussing the impact of COVID-19 on her detention and ability to prepare for her defense. The text is mostly printed, with some footnotes and citations. There are no visible stamps or handwritten text."
}