mirror-epstein-docs/results/IMAGES002/DOJ-OGR-00005452.json

{
  "document_metadata": {
    "page_number": "2",
    "document_number": "381",
    "date": "10/29/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 381 Filed 10/29/21 Page 2 of 5\n\nnow a month away from trial and any delay receiving her legal mail impedes her ability to adequately prepare for trial.\n\nFurther, Ms. Maxwell is not receiving disclosures sent via Federal Express by the government in a timely manner. We have requested that within a month of commencement of trial, government disclosures be hand delivered to the MDC to alleviate delivery delays. The government has declined this request, again claiming resource issues. There is no assurance that Ms. Maxwell will receive legal mail - critical to trial preparation - in a timely manner. This is yet another example of how pretrial detention is encumbering Ms. Maxwell's ability to prepare for trial and interfering with her ability to effectively communicate with counsel. This should undermine the Court's confidence that Ms. Maxwell and her attorneys will be fully able to prepare for trial.\n\nVery truly yours,\n\n/s/\nBOBBI C. STERNHEIM\n\ncc: All counsel of record\n\n2\nDOJ-OGR-00005452",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 381 Filed 10/29/21 Page 2 of 5",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "now a month away from trial and any delay receiving her legal mail impedes her ability to adequately prepare for trial.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Further, Ms. Maxwell is not receiving disclosures sent via Federal Express by the government in a timely manner. We have requested that within a month of commencement of trial, government disclosures be hand delivered to the MDC to alleviate delivery delays. The government has declined this request, again claiming resource issues. There is no assurance that Ms. Maxwell will receive legal mail - critical to trial preparation - in a timely manner. This is yet another example of how pretrial detention is encumbering Ms. Maxwell's ability to prepare for trial and interfering with her ability to effectively communicate with counsel. This should undermine the Court's confidence that Ms. Maxwell and her attorneys will be fully able to prepare for trial.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Very truly yours,",
      "position": "middle"
    },
    {
      "type": "signature",
      "content": "/s/",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "BOBBI C. STERNHEIM",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "cc: All counsel of record",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "2",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00005452",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Ms. Maxwell",
      "BOBBI C. STERNHEIM"
    ],
    "organizations": [
      "MDC"
    ],
    "locations": [],
    "dates": [
      "10/29/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "381",
      "DOJ-OGR-00005452"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Ms. Maxwell, discussing issues with her pretrial detention and access to legal mail. The document is well-formatted and free of significant damage or redactions."
}