mirror-epstein-docs/results/IMAGES001/DOJ-OGR-00001287.json

{
  "document_metadata": {
    "page_number": null,
    "document_number": "20 Cr. 330 (AJN)",
    "date": "February 16, 2021",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "LAW OFFICES OF BOBBI C. STERNHEIM\n212-243-1100 • Main\n917-306-6666 • Cell\n888-587-4737 • Fax\n33 West 19th Street - 4th Floor\nNew York, New York 10011\nbc@sternheimlaw.com\n\nFebruary 16, 2021\n\nHonorable Alison J. Nathan\nUnited States District Court\nUnited States Courthouse\n40 Foley Square\nNew York, NY 10007\n\nRe: United States v. Ghislaine Maxwell\n20 Cr. 330 (AJN)\n\nDear Judge Nathan:\n\nThe government's recent letter regarding MDC conditions (Dkt.158) essentially repeats the same points it made in defense of the MDC's request that the Court vacate its order directing the MDC to permit Ms. Maxwell to use a laptop on weekends and holidays. We appreciate the Court's concern regarding Ms. Maxwell's opportunity to review discovery and the extent to which she is required to undergo searches. The government's letter, however, does not include the concerns defense counsel has reported to MDC Legal during the past couple of months. In addition, the letter incorrectly states that legal calls are available on Saturdays. Such requests by counsel have been denied.\n\nBy ignoring the myriad other issues reported by counsel, the government's letter misrepresents Ms. Maxwell's conditions of confinement. Ms. Maxwell does not have access to daily discovery review for the entirety of the 13 hours. The vagaries and delays of moving her the 50 feet or so from the isolation cell to the day room are a large part of the challenge.\n\nThe number of searches is also not correct. Ms. Maxwell is searched on every move, including to the empty concrete space, adjacent to the day room, used for recreation. Currently, she is subject to a minimum of four pat down searches a day if she goes to rec, and five pat down searches on the day of her weekly body scan. Since July 6th, Ms. Maxwell has been physically searched approximately 1400 times, including pat down searches, metal wand searches, mouth, hair and ear searches (posing additional health risks during COVID), and upwards of 60 body scans. In addition, there have been hundreds of physical searches of her isolation cell, locker, legal papers, and personal effects. No contraband has ever been found.\n\nWe take issue with MDC's assessment that \"the searches are all necessary for the safety of the institution and the defendant.\" Ms. Maxwell is under 24-hour surveillance by two to six guards and approximately 18 cameras, not including the hand-held camera, focused on her throughout the areas in which she is moved and confined. Ms. Maxwell poses no danger to anyone. Her restrictive conditions, searches, and constant surveillance correlate directly to BOP negligence resulting in the death of Jeffrey Epstein.\n\nDOJ-OGR-00001287",
  "text_blocks": [
    {
      "type": "printed",
      "content": "LAW OFFICES OF BOBBI C. STERNHEIM\n212-243-1100 • Main\n917-306-6666 • Cell\n888-587-4737 • Fax\n33 West 19th Street - 4th Floor\nNew York, New York 10011\nbc@sternheimlaw.com",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "February 16, 2021",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Honorable Alison J. Nathan\nUnited States District Court\nUnited States Courthouse\n40 Foley Square\nNew York, NY 10007",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Re: United States v. Ghislaine Maxwell\n20 Cr. 330 (AJN)",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Dear Judge Nathan:",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The government's recent letter regarding MDC conditions (Dkt.158) essentially repeats the same points it made in defense of the MDC's request that the Court vacate its order directing the MDC to permit Ms. Maxwell to use a laptop on weekends and holidays. We appreciate the Court's concern regarding Ms. Maxwell's opportunity to review discovery and the extent to which she is required to undergo searches. The government's letter, however, does not include the concerns defense counsel has reported to MDC Legal during the past couple of months. In addition, the letter incorrectly states that legal calls are available on Saturdays. Such requests by counsel have been denied.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "By ignoring the myriad other issues reported by counsel, the government's letter misrepresents Ms. Maxwell's conditions of confinement. Ms. Maxwell does not have access to daily discovery review for the entirety of the 13 hours. The vagaries and delays of moving her the 50 feet or so from the isolation cell to the day room are a large part of the challenge.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The number of searches is also not correct. Ms. Maxwell is searched on every move, including to the empty concrete space, adjacent to the day room, used for recreation. Currently, she is subject to a minimum of four pat down searches a day if she goes to rec, and five pat down searches on the day of her weekly body scan. Since July 6th, Ms. Maxwell has been physically searched approximately 1400 times, including pat down searches, metal wand searches, mouth, hair and ear searches (posing additional health risks during COVID), and upwards of 60 body scans. In addition, there have been hundreds of physical searches of her isolation cell, locker, legal papers, and personal effects. No contraband has ever been found.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "We take issue with MDC's assessment that \"the searches are all necessary for the safety of the institution and the defendant.\" Ms. Maxwell is under 24-hour surveillance by two to six guards and approximately 18 cameras, not including the hand-held camera, focused on her throughout the areas in which she is moved and confined. Ms. Maxwell poses no danger to anyone. Her restrictive conditions, searches, and constant surveillance correlate directly to BOP negligence resulting in the death of Jeffrey Epstein.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00001287",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ghislaine Maxwell",
      "Jeffrey Epstein",
      "Bobbi C. Sternheim"
    ],
    "organizations": [
      "United States District Court",
      "MDC",
      "BOP",
      "LAW OFFICES OF BOBBI C. STERNHEIM"
    ],
    "locations": [
      "New York",
      "United States Courthouse",
      "40 Foley Square"
    ],
    "dates": [
      "February 16, 2021",
      "July 6th"
    ],
    "reference_numbers": [
      "20 Cr. 330 (AJN)",
      "Dkt.158",
      "DOJ-OGR-00001287"
    ]
  },
  "additional_notes": "The document is a letter from Bobbi C. Sternheim to Honorable Alison J. Nathan regarding the conditions of confinement of Ghislaine Maxwell. The letter is typed and appears to be a formal legal document."
}