{
  "document_metadata": {
    "page_number": "2",
    "document_number": "22433",
    "date": null,
    "document_type": "letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "LAW OFFICES OF BOBBI C. STERNHEIM\n\nI emailed the following response to Ms. Papapetru:\n\nYour accusation is inaccurate as is the information reported to you by your staff. Nothing in Ms. Maxwell's legal papers was given to her by me or by Leah Saffian, Esq. Both Ms. Saffian and I dispute these allegations in the strongest terms. Today, Ms. Saffian and I met with Ghislaine Maxwell for a scheduled legal visit- under the gaze of 5 guards and a portable camera recording audio and video.\n\nAfter the legal visit concluded and Ms. Saffian and I left the visiting area, guards accused Ms. Maxwell of possessing documents obtained from counsel. The guards seized confidential documents from her, including documents she had previously received in legal mail delivered to the MDC and given to her by MDC staff. After seizing \"highly confidential\" documents (subject to a protective order that your staff is not authorized to review) and work product, the guards began reading the documents and have not returned them to Ms. Maxwell.\n\nAt no time did the guards, who were assiduously watching and filming the legal conference, bring any concern to my attention, so it is quite telling that you have been contacted when counsel are told that legal staff are unavailable during the weekend.\n\nNo documents were given to Ms. Maxwell for her retention. Demand is hereby made for an immediate identification of the documents you claim were not in Ms. Maxwell's possession upon entering the legal visiting area in advance of the arrival of counsel, a list of all guards present during the visit, and a copy of the video recording.\n\nPlease immediately return the confiscated legal documents to Ms. Maxwell. They are her documents, not mine. The confiscation of these documents has deprived Ms. Maxwell of her time and seriously impaired her ability to review legal documents and prepare for an upcoming trial, adding to an already difficult situation.\n\nThis matter is being reported to the Court and legal action will be initiated.\n\nSee Exhibit B.\n\nA notice and demand to preserve items of evidence has been sent to Ms. Papapetru. See Exhibit C.\n\nConfiscation and Review of Confidential Legal Documents\n\nIn advance of previous in-person legal visits, guards have gone through Ms. Maxwell's legal papers. In a break from such protocol, the guards did not do so prior to commencement of the legal visit on Saturday.\n\nAfter the legal conference and departure of counsel, the guards seized all of Ms. Maxwell's legal papers, consisting of multiple letter-sized manilla folders containing documents and a composition notebook within a Redweld folder. The guards told Ms. Maxwell they believed she improperly retained documents given to her by her attorneys and that this was a\n\n2\n\nDOJ-OGR-00004028",
  "text_blocks": [
    {
      "type": "printed",
      "content": "LAW OFFICES OF BOBBI C. STERNHEIM",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "I emailed the following response to Ms. Papapetru:\n\nYour accusation is inaccurate as is the information reported to you by your staff. Nothing in Ms. Maxwell's legal papers was given to her by me or by Leah Saffian, Esq. Both Ms. Saffian and I dispute these allegations in the strongest terms. Today, Ms. Saffian and I met with Ghislaine Maxwell for a scheduled legal visit- under the gaze of 5 guards and a portable camera recording audio and video.\n\nAfter the legal visit concluded and Ms. Saffian and I left the visiting area, guards accused Ms. Maxwell of possessing documents obtained from counsel. The guards seized confidential documents from her, including documents she had previously received in legal mail delivered to the MDC and given to her by MDC staff. After seizing \"highly confidential\" documents (subject to a protective order that your staff is not authorized to review) and work product, the guards began reading the documents and have not returned them to Ms. Maxwell.\n\nAt no time did the guards, who were assiduously watching and filming the legal conference, bring any concern to my attention, so it is quite telling that you have been contacted when counsel are told that legal staff are unavailable during the weekend.\n\nNo documents were given to Ms. Maxwell for her retention. Demand is hereby made for an immediate identification of the documents you claim were not in Ms. Maxwell's possession upon entering the legal visiting area in advance of the arrival of counsel, a list of all guards present during the visit, and a copy of the video recording.\n\nPlease immediately return the confiscated legal documents to Ms. Maxwell. They are her documents, not mine. The confiscation of these documents has deprived Ms. Maxwell of her time and seriously impaired her ability to review legal documents and prepare for an upcoming trial, adding to an already difficult situation.\n\nThis matter is being reported to the Court and legal action will be initiated.\n\nSee Exhibit B.\n\nA notice and demand to preserve items of evidence has been sent to Ms. Papapetru. See Exhibit C.",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "Confiscation and Review of Confidential Legal Documents",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "In advance of previous in-person legal visits, guards have gone through Ms. Maxwell's legal papers. In a break from such protocol, the guards did not do so prior to commencement of the legal visit on Saturday.\n\nAfter the legal conference and departure of counsel, the guards seized all of Ms. Maxwell's legal papers, consisting of multiple letter-sized manilla folders containing documents and a composition notebook within a Redweld folder. The guards told Ms. Maxwell they believed she improperly retained documents given to her by her attorneys and that this was a",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "2",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00004028",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Ms. Papapetru",
      "Leah Saffian",
      "Ghislaine Maxwell",
      "Bobbi C. Sternheim"
    ],
    "organizations": [
      "MDC",
      "LAW OFFICES OF BOBBI C. STERNHEIM",
      "Court"
    ],
    "locations": [],
    "dates": [],
    "reference_numbers": [
      "22433",
      "DOJ-OGR-00004028"
    ]
  },
  "additional_notes": "The document appears to be a formal letter or legal document from the Law Offices of Bobbi C. Sternheim regarding an incident involving Ghislaine Maxwell and the confiscation of her legal documents. The document is typed and contains no handwritten text or stamps."
}