{
  "document_metadata": {
    "page_number": "1",
    "document_number": "248",
    "date": "04/26/21",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 248 Filed 04/26/21 Page 1 of 9 LAW OFFICES OF BOBBI C. STERNHEIM 212-243-1100 * Main 917-306-6666 * Cell 888-587-4737 * Fax 33 West 19th Street - 4th Floor New York, New York 10011 bc@sternheimlaw.com April 26, 2021 Honorable Alison J. Nathan United States District Judge United States Courthouse 40 Foley Square New York, NY 10007 Re: United States v. Ghislaine Maxwell S2 20 Cr. 330 (AJN) Dear Judge Nathan: I write to report an incident stemming from an attorney-client conference with Ghislaine Maxwell: Guards on Ms. Maxwell's security detail wrongfully seized and reviewed her confidential legal documents and then intimidated Ms. Maxwell by standing over her as she used the bathroom after threatening her with a disciplinary infraction. This incident has further compromised Ms. Maxwell's ability to prepare for trial, to confer with counsel, and to retain confidential legal documents. In addition, intimidation and humiliation by guards has further exacerbated Ms. Maxwell's feelings of insecurity due to officious power exerted upon her by guards. On Saturday, April 24, 2021, Leah Saffian, Esq. and I attended a pre-scheduled in-person legal conference with Ms. Maxwell in the MDC. The entire 2.5-hour conference was conducted under the constant watch of four to five guards, including a lieutenant, with a camera on a tripod focused on Ms. Maxwell and counsel while recording audio and video, and captured on surveillance cameras affixed within the visiting room. After counsel left the facility, Ms. Maxwell called me to report that her legal papers were confiscated. Later that day, I received an email from Sophia Papapetru, MDC legal counsel, which stated: It has been brought to my attention by the staff of MDC Brooklyn that Ms. Maxwell received paperwork that was not in her possession upon entering the legal visiting area. As you are aware, the policies set forth for MDC Brooklyn legal visits do not allow for passing of any material during a legal visit. Due to our policy and procedures, the additional documents that were provided to Ms. Maxwell were confiscated. Those materials were put in an envelope and will be returned to you tomorrow upon your arrival to the institution. Please note, that you may put these documents in the legal mailbox in the lobby of the east building. See Exhibit A. DOJ-OGR-00004018",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 248 Filed 04/26/21 Page 1 of 9",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "LAW OFFICES OF BOBBI C. STERNHEIM",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "212-243-1100 * Main 917-306-6666 * Cell 888-587-4737 * Fax 33 West 19th Street - 4th Floor New York, New York 10011 bc@sternheimlaw.com",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "April 26, 2021",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Honorable Alison J. Nathan United States District Judge United States Courthouse 40 Foley Square New York, NY 10007",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Re: United States v. Ghislaine Maxwell S2 20 Cr. 330 (AJN)",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Dear Judge Nathan: I write to report an incident stemming from an attorney-client conference with Ghislaine Maxwell: Guards on Ms. Maxwell's security detail wrongfully seized and reviewed her confidential legal documents and then intimidated Ms. Maxwell by standing over her as she used the bathroom after threatening her with a disciplinary infraction. This incident has further compromised Ms. Maxwell's ability to prepare for trial, to confer with counsel, and to retain confidential legal documents. In addition, intimidation and humiliation by guards has further exacerbated Ms. Maxwell's feelings of insecurity due to officious power exerted upon her by guards.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "On Saturday, April 24, 2021, Leah Saffian, Esq. and I attended a pre-scheduled in-person legal conference with Ms. Maxwell in the MDC. The entire 2.5-hour conference was conducted under the constant watch of four to five guards, including a lieutenant, with a camera on a tripod focused on Ms. Maxwell and counsel while recording audio and video, and captured on surveillance cameras affixed within the visiting room. After counsel left the facility, Ms. Maxwell called me to report that her legal papers were confiscated.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Later that day, I received an email from Sophia Papapetru, MDC legal counsel, which stated: It has been brought to my attention by the staff of MDC Brooklyn that Ms. Maxwell received paperwork that was not in her possession upon entering the legal visiting area. As you are aware, the policies set forth for MDC Brooklyn legal visits do not allow for passing of any material during a legal visit. Due to our policy and procedures, the additional documents that were provided to Ms. Maxwell were confiscated. Those materials were put in an envelope and will be returned to you tomorrow upon your arrival to the institution. Please note, that you may put these documents in the legal mailbox in the lobby of the east building.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "See Exhibit A.",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00004018",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ghislaine Maxwell",
      "Leah Saffian",
      "Sophia Papapetru"
    ],
    "organizations": [
      "Law Offices of Bobbi C. Sternheim",
      "United States District Court",
      "MDC Brooklyn"
    ],
    "locations": [
      "New York",
      "United States Courthouse",
      "40 Foley Square",
      "MDC Brooklyn",
      "East Building"
    ],
    "dates": [
      "April 26, 2021",
      "April 24, 2021"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 248",
      "S2 20 Cr. 330 (AJN)",
      "DOJ-OGR-00004018"
    ]
  },
  "additional_notes": "The document appears to be a formal letter from a law office to a judge regarding an incident involving Ghislaine Maxwell. The letter is typed and contains no handwritten text or stamps. The document is well-formatted and legible."
}