{
  "document_metadata": {
    "page_number": "1",
    "document_number": "20-cr-00330",
    "date": "February 4, 2021",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 258-2 Filed 02/07/21 Page 1 of 2\nU.S. Department of Justice\nUnited States Attorney\nSouthern District of New York\nThe Silvio J. Mollo Building\nOne Saint Andrew's Plaza\nNew York, New York 10007\nFebruary 4, 2021\nBY ECF\nThe Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\nUnited States Courthouse\n40 Foley Square\nNew York, New York 10007\nRe: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)\nDear Judge Nathan:\nThe Government respectfully submits this letter to provide an update regarding the defendant's conditions of confinement at the Metropolitan Detention Center (\"MDC\") pursuant to the Court's Order dated December 8, 2020. (Dkt. No. 92). Over the past two months, the Government has had multiple communications with MDC legal counsel regarding the defendant's conditions of confinement. This update is based on information provided to the Government by MDC legal counsel through those communications.\nThe defendant continues to receive more time to review discovery than any other inmate at the MDC. Specifically, the defendant is permitted to review her discovery thirteen hours per day, seven days per week. During the entirety of that time, the defendant has access to a desktop computer provided by the MDC on which to review discovery. Additionally, pursuant to the Court's January 15, 2021 Order, the defendant also has access to a laptop computer provided by the Government on which to review discovery for the full thirteen hours per day, seven days per week. Also during those thirteen hours per day, the defendant may use the MDC desktop computer to send and receive emails with her attorneys.\nThe defendant also has as much, if not more, time as any other MDC inmate to communicate with her attorneys. Due to the elevated number of COVID-19 cases within the MDC, in-person visits have been suspended since in or about December 2020. While in-person visits are suspended, the defendant has had regular video-teleconference (\"VTC\") calls with her counsel. In particular, the defendant has VTC calls with her counsel every weekday for three hours per call. If defense counsel requires additional time to speak with the defendant, counsel may request to schedule an additional phone call on Saturdays as needed. All of these VTCs and telephone calls take place in a room where the defendant is alone and where no MDC staff can hear her communications with counsel.\nThe defendant's legal mail is processed in the same manner as mail for all other inmates at the MDC. All inmate mail is sent to the MDC's mail room, where every piece of mail is processed\nDOJ-OGR-00001357",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 258-2 Filed 02/07/21 Page 1 of 2",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "U.S. Department of Justice\nUnited States Attorney\nSouthern District of New York\nThe Silvio J. Mollo Building\nOne Saint Andrew's Plaza\nNew York, New York 10007",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "February 4, 2021",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "BY ECF",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "The Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\nUnited States Courthouse\n40 Foley Square\nNew York, New York 10007",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Dear Judge Nathan:",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "The Government respectfully submits this letter to provide an update regarding the defendant's conditions of confinement at the Metropolitan Detention Center (\"MDC\") pursuant to the Court's Order dated December 8, 2020. (Dkt. No. 92). Over the past two months, the Government has had multiple communications with MDC legal counsel regarding the defendant's conditions of confinement. This update is based on information provided to the Government by MDC legal counsel through those communications.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "The defendant continues to receive more time to review discovery than any other inmate at the MDC. Specifically, the defendant is permitted to review her discovery thirteen hours per day, seven days per week. During the entirety of that time, the defendant has access to a desktop computer provided by the MDC on which to review discovery. Additionally, pursuant to the Court's January 15, 2021 Order, the defendant also has access to a laptop computer provided by the Government on which to review discovery for the full thirteen hours per day, seven days per week. Also during those thirteen hours per day, the defendant may use the MDC desktop computer to send and receive emails with her attorneys.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "The defendant also has as much, if not more, time as any other MDC inmate to communicate with her attorneys. Due to the elevated number of COVID-19 cases within the MDC, in-person visits have been suspended since in or about December 2020. While in-person visits are suspended, the defendant has had regular video-teleconference (\"VTC\") calls with her counsel. In particular, the defendant has VTC calls with her counsel every weekday for three hours per call. If defense counsel requires additional time to speak with the defendant, counsel may request to schedule an additional phone call on Saturdays as needed. All of these VTCs and telephone calls take place in a room where the defendant is alone and where no MDC staff can hear her communications with counsel.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "The defendant's legal mail is processed in the same manner as mail for all other inmates at the MDC. All inmate mail is sent to the MDC's mail room, where every piece of mail is processed",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00001357",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ghislaine Maxwell"
    ],
    "organizations": [
      "U.S. Department of Justice",
      "United States Attorney",
      "Southern District of New York",
      "Metropolitan Detention Center"
    ],
    "locations": [
      "New York",
      "United States Courthouse",
      "40 Foley Square"
    ],
    "dates": [
      "February 4, 2021",
      "December 8, 2020",
      "January 15, 2021",
      "December 2020"
    ],
    "reference_numbers": [
      "20 Cr. 330 (AJN)",
      "Dkt. No. 92",
      "DOJ-OGR-00001357"
    ]
  },
  "additional_notes": "The document appears to be a formal letter from the U.S. Department of Justice to the Honorable Alison J. Nathan regarding the conditions of confinement of Ghislaine Maxwell at the Metropolitan Detention Center."
}