mirror-epstein-docs/results/IMAGES001/DOJ-OGR-00002886.json

{
  "document_metadata": {
    "page_number": "3 of 3",
    "document_number": "192",
    "date": "03/31/21",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 192 Filed 03/31/21 Page 3 of 3\nLAW OFFICES OF BOBBI C. STERNHEIM\n\nMs. Maxwell is entitled to a fair trial with effective assistance of counsel. If counsel feel that additional time is required to guarantee those constitutional rights, Ms. Maxwell will suffer the consequence by her continued detention. The Court has the power - and, indeed, the discretion - to accommodate this constitutional clash. Granting a continuance and releasing Ms. Maxwell on the most restrictive conditions of home detention. Surely, the Court can impose conditions that \"clip her wings\" and satisfy perceived flight concerns without keeping Ms. Maxwell locked in a BOP cage.\n\nAs counsel has notified the government, Ms. Maxwell is requesting an in-person arraignment. She will not waive that right, most especially in light of media coverage and the debacle that occurred during a remote proceeding in a related civil case before Judge Preska. In addition, Ms. Maxwell is requesting a bail hearing at which witnesses will testify regarding the purported strength of the government's case. Further, we request that these proceedings be scheduled to coincide with an evidence review session at the U.S. Attorney's Office to be attended by Ms. Maxwell with counsel.\n\nYour consideration is greatly appreciated.\n\nVery truly yours,\nBobbi C. Sternheim\nBOBBI C. STERNHEIM\n\ncc: All counsel\n\n3\nDOJ-OGR-00002886",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 192 Filed 03/31/21 Page 3 of 3",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "LAW OFFICES OF BOBBI C. STERNHEIM",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Ms. Maxwell is entitled to a fair trial with effective assistance of counsel. If counsel feel that additional time is required to guarantee those constitutional rights, Ms. Maxwell will suffer the consequence by her continued detention. The Court has the power - and, indeed, the discretion - to accommodate this constitutional clash. Granting a continuance and releasing Ms. Maxwell on the most restrictive conditions of home detention. Surely, the Court can impose conditions that \"clip her wings\" and satisfy perceived flight concerns without keeping Ms. Maxwell locked in a BOP cage.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "As counsel has notified the government, Ms. Maxwell is requesting an in-person arraignment. She will not waive that right, most especially in light of media coverage and the debacle that occurred during a remote proceeding in a related civil case before Judge Preska. In addition, Ms. Maxwell is requesting a bail hearing at which witnesses will testify regarding the purported strength of the government's case. Further, we request that these proceedings be scheduled to coincide with an evidence review session at the U.S. Attorney's Office to be attended by Ms. Maxwell with counsel.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Your consideration is greatly appreciated.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Very truly yours,",
      "position": "body"
    },
    {
      "type": "signature",
      "content": "Bobbi C. Sternheim",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "BOBBI C. STERNHEIM",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "cc: All counsel",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "3",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00002886",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Ms. Maxwell",
      "Bobbi C. Sternheim",
      "Judge Preska"
    ],
    "organizations": [
      "U.S. Attorney's Office",
      "LAW OFFICES OF BOBBI C. STERNHEIM"
    ],
    "locations": [],
    "dates": [
      "03/31/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "Document 192",
      "DOJ-OGR-00002886"
    ]
  },
  "additional_notes": "The document appears to be a formal letter from Bobbi C. Sternheim to an unspecified recipient, discussing the case of Ms. Maxwell and requesting certain accommodations and actions from the court."
}