{
  "document_metadata": {
    "page_number": "2 of 4",
    "document_number": "256",
    "date": "04/29/21",
    "document_type": "Letter",
    "has_handwriting": true,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 256 Filed 04/29/21 Page 2 of 4\nLAW OFFICES OF BOBBI C. STERNHEIM\n\nThe MDC routinely places inmates in the SHU if they have engaged in physical altercation with other inmates or to protect inmates who are the subject of abuse. It would be ironic if the MDC follows through with its threat to place Ms. Maxwell in the SHU: It would signal that Ms. Maxwell needs protection from the very staff so intent on protecting her, since she has no contact with anyone but staff.\n\nAs suggested by the Circuit, we ask the Court to address Ms. Maxwell's sleeping conditions by directing the MDC to cease 15-minute light surveillance of Ms. Maxwell or justify the need for the disruptive flashlight surveillance.\n\nVery truly yours,\n\nBobbi C. Sternheim\nBOBBI C. STERNHEIM\n\nEncs.\ncc: All counsel of record\n\n2\nDOJ-OGR-00004055",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 256 Filed 04/29/21 Page 2 of 4",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "LAW OFFICES OF BOBBI C. STERNHEIM",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "The MDC routinely places inmates in the SHU if they have engaged in physical altercation with other inmates or to protect inmates who are the subject of abuse. It would be ironic if the MDC follows through with its threat to place Ms. Maxwell in the SHU: It would signal that Ms. Maxwell needs protection from the very staff so intent on protecting her, since she has no contact with anyone but staff.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "As suggested by the Circuit, we ask the Court to address Ms. Maxwell's sleeping conditions by directing the MDC to cease 15-minute light surveillance of Ms. Maxwell or justify the need for the disruptive flashlight surveillance.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Very truly yours,",
      "position": "middle"
    },
    {
      "type": "handwritten",
      "content": "Bobbi C. Sternheim",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "BOBBI C. STERNHEIM",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Encs.\ncc: All counsel of record",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "2",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00004055",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Bobbi C. Sternheim",
      "Ms. Maxwell"
    ],
    "organizations": [
      "MDC",
      "Circuit",
      "Court",
      "LAW OFFICES OF BOBBI C. STERNHEIM"
    ],
    "locations": [],
    "dates": [
      "04/29/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "256",
      "DOJ-OGR-00004055"
    ]
  },
  "additional_notes": "The document appears to be a letter from Bobbi C. Sternheim to the Court regarding the conditions of Ms. Maxwell's imprisonment. The document is well-formatted and legible, with a clear signature from Bobbi C. Sternheim."
}