{ "document_metadata": { "page_number": "2", "document_number": "20-cr-00880", "date": null, "document_type": "Court Document", "has_handwriting": false, "has_stamps": false }, "full_text": "Case#: 20-cr-00880 Adjnt Bocument 77/01 Filed 01/12/21 Page 220f 2 Page 2 searching (e.g., weekly body scan, 15-minute interval flashlight checks at night, and open-mouth inspection) despite being surveilled 24/7 by a dedicated three-guard security detail and two cameras; and the reason she is not being moved to the day room, which we understood was the original plan (and would reduce searching). Receipt of the letter was acknowledged, but to date there has been no response and little, if any, redress to the most serious conditions. Upon information and belief, decisions concerning Ms. Maxwell's specialized detention are made by Warden Tellez, or from others outside the MDC. A report from the MDC Legal Department would provide second-hand information. Accordingly, Warden Tellez should be directed to provide a first-hand accounting to the Court and counsel why Ms. Maxwell is being detained under such individualized conditions. Your consideration is greatly appreciated. Respectfully submitted, AUDREY STRAUSS Acting United States Attorney By: s/ Maurene Comey / Alison Moe / Lara Pomerantz Assistant United States Attorneys Southern District of New York Tel: (212) 637-2324 Cc: All Counsel of Record (By ECF) DOJ-OGR-00001346", "text_blocks": [ { "type": "printed", "content": "Case#: 20-cr-00880 Adjnt Bocument 77/01 Filed 01/12/21 Page 220f 2", "position": "header" }, { "type": "printed", "content": "Page 2", "position": "header" }, { "type": "printed", "content": "searching (e.g., weekly body scan, 15-minute interval flashlight checks at night, and open-mouth inspection) despite being surveilled 24/7 by a dedicated three-guard security detail and two cameras; and the reason she is not being moved to the day room, which we understood was the original plan (and would reduce searching). Receipt of the letter was acknowledged, but to date there has been no response and little, if any, redress to the most serious conditions. Upon information and belief, decisions concerning Ms. Maxwell's specialized detention are made by Warden Tellez, or from others outside the MDC. A report from the MDC Legal Department would provide second-hand information. Accordingly, Warden Tellez should be directed to provide a first-hand accounting to the Court and counsel why Ms. Maxwell is being detained under such individualized conditions.", "position": "middle" }, { "type": "printed", "content": "Your consideration is greatly appreciated.", "position": "middle" }, { "type": "printed", "content": "Respectfully submitted,", "position": "middle" }, { "type": "printed", "content": "AUDREY STRAUSS Acting United States Attorney", "position": "middle" }, { "type": "printed", "content": "By: s/ Maurene Comey / Alison Moe / Lara Pomerantz Assistant United States Attorneys Southern District of New York Tel: (212) 637-2324", "position": "middle" }, { "type": "printed", "content": "Cc: All Counsel of Record (By ECF)", "position": "middle" }, { "type": "printed", "content": "DOJ-OGR-00001346", "position": "footer" } ], "entities": { "people": [ "Ms. Maxwell", "Warden Tellez", "AUDREY STRAUSS", "Maurene Comey", "Alison Moe", "Lara Pomerantz" ], "organizations": [ "MDC Legal Department", "Southern District of New York" ], "locations": [ "New York" ], "dates": [ "01/12/21" ], "reference_numbers": [ "20-cr-00880", "DOJ-OGR-00001346" ] }, "additional_notes": "The document appears to be a court filing related to the detention of Ms. Maxwell. The text is mostly printed, with a signature block containing the names of the Assistant United States Attorneys. The document is well-formatted and legible." }