mirror-epstein-docs/results/IMAGES001/DOJ-OGR-00002273.json

{
  "document_metadata": {
    "page_number": "2 of 3",
    "document_number": "117",
    "date": "January 25, 2021",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": true
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 117 Filed 01/25/21 Page 2 of 3\nU.S. DEPARTMENT OF JUSTICE\nFederal Bureau of Prisons\nMetropolitan Detention Center\n80 29th Street\nBrooklyn, New York 11232\nJanuary 25, 2021\nBY ECF\nThe Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\n40 Foley Square\nNew York, NY 10007\nRe: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)\nGhislaine Maxwell, Reg. No. 02879-509\nDear Judge Nathan:\nThis letter is written in response to Order granted on January 15, 2021, concerning Ghislaine Maxwell, Reg. 02879-509., an inmate currently confined at the Metropolitan Detention Center (\"MDC\") in Brooklyn, New York. The MDC Brooklyn respectfully requests that Your Honor vacate the Order given MDC Brooklyn was not given the opportunity to object to defense counsel's claims, although the objection had been reiterated to the U.S. Attorney's Office numerous times.\nDefense counsel expressed various concerns regarding Ms. Maxwell's confinement limiting her access to discovery. However, Ms. Maxwell has received a significant amount of time to review her discovery. On November 18, 2020, the Government provided the MDC Brooklyn with a laptop for Ms. Maxwell to use to review discovery. Ms. Maxwell has been and will continue to be permitted to use that laptop to review her discovery for thirteen (13) hours per day, five (5) days per week. In addition to the Government laptop, she has access to the MDC Brooklyn discovery computers. Although defense counsel has indicated that the MDC Brooklyn discovery computers are not equipped to read all of her electronic discovery, the computers are capable of reviewing most of the electronic discovery. Despite defense counsel's claim that Ms. Maxwell's lacks sufficient time to fully review her discovery, her consistent use of Government laptop and MDC Brooklyn's discovery computers undercuts this claim.\nMoreover, Ms. Maxwell continues to have contact with her legal counsel five (5) days per week, three (3) hours per day via video-teleconference and via telephone; this is far more time than any other MDC inmate is allotted to communicate with their attorneys.\nDOJ-OGR-00002273",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 117 Filed 01/25/21 Page 2 of 3",
      "position": "header"
    },
    {
      "type": "stamp",
      "content": "U.S. DEPARTMENT OF JUSTICE\nFederal Bureau of Prisons\nMetropolitan Detention Center",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "80 29th Street\nBrooklyn, New York 11232\nJanuary 25, 2021",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "BY ECF\nThe Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\n40 Foley Square\nNew York, NY 10007",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)\nGhislaine Maxwell, Reg. No. 02879-509",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Dear Judge Nathan:\nThis letter is written in response to Order granted on January 15, 2021, concerning Ghislaine Maxwell, Reg. 02879-509., an inmate currently confined at the Metropolitan Detention Center (\"MDC\") in Brooklyn, New York. The MDC Brooklyn respectfully requests that Your Honor vacate the Order given MDC Brooklyn was not given the opportunity to object to defense counsel's claims, although the objection had been reiterated to the U.S. Attorney's Office numerous times.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Defense counsel expressed various concerns regarding Ms. Maxwell's confinement limiting her access to discovery. However, Ms. Maxwell has received a significant amount of time to review her discovery. On November 18, 2020, the Government provided the MDC Brooklyn with a laptop for Ms. Maxwell to use to review discovery. Ms. Maxwell has been and will continue to be permitted to use that laptop to review her discovery for thirteen (13) hours per day, five (5) days per week. In addition to the Government laptop, she has access to the MDC Brooklyn discovery computers. Although defense counsel has indicated that the MDC Brooklyn discovery computers are not equipped to read all of her electronic discovery, the computers are capable of reviewing most of the electronic discovery. Despite defense counsel's claim that Ms. Maxwell's lacks sufficient time to fully review her discovery, her consistent use of Government laptop and MDC Brooklyn's discovery computers undercuts this claim.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Moreover, Ms. Maxwell continues to have contact with her legal counsel five (5) days per week, three (3) hours per day via video-teleconference and via telephone; this is far more time than any other MDC inmate is allotted to communicate with their attorneys.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00002273",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ghislaine Maxwell"
    ],
    "organizations": [
      "U.S. Department of Justice",
      "Federal Bureau of Prisons",
      "Metropolitan Detention Center",
      "United States District Court",
      "Southern District of New York",
      "U.S. Attorney's Office"
    ],
    "locations": [
      "Brooklyn",
      "New York"
    ],
    "dates": [
      "January 25, 2021",
      "January 15, 2021",
      "November 18, 2020"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "Document 117",
      "20 Cr. 330 (AJN)",
      "Reg. No. 02879-509",
      "DOJ-OGR-00002273"
    ]
  },
  "additional_notes": "The document appears to be a formal letter from the Metropolitan Detention Center to Judge Alison J. Nathan regarding Ghislaine Maxwell's confinement and access to discovery materials. The letterhead includes the U.S. Department of Justice and Federal Bureau of Prisons logos. The document is typed and contains no handwritten text."
}