mirror-epstein-docs/results/IMAGES001/DOJ-OGR-00001837.json

{
  "document_metadata": {
    "page_number": "1",
    "document_number": "75",
    "date": "11/24/20",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 75 Filed 11/24/20 Page 1 of 2\nLAW 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\nNovember 24, 2020\nHonorable Alison J. Nathan\nUnited States District Judge\nUnited States Courthouse\n40 Foley Square\nNew York, NY 10007\nRe: United States v. Ghislaine Maxwell\n20 Cr. 330 (AJN)\nDear Judge Nathan:\nAs counsel for Ghislaine Maxwell, I write in response to the government's letter, dated November 23, 2020 (see Dkt 74), reporting Ms. Maxwell's conditions of detention and confirming that she is currently in quarantine due to contact with a staff member, assigned to her isolation pod, who tested positive for COVID-19.\nThe government recites a variety of allowances given Ms. Maxwell, including being permitted out of her cell three times a week during quarantine for a maximum of 30 minutes, the total time allotted for showering, making personal calls, and using the CorrLinks email system to communicate with family and counsel. However, the letter presents an incomplete picture of Ms. Maxwell's conditions of confinement.\nThe government fails to mention a variety of issues brought to the attention of the MDC, including but not limited to the fact: that all email correspondence between Ms. Maxwell and counsel was deleted in advance of the 180-day period, when deletion is expected to occur; that after being administered two nasal swab tests, under threat of 21-day quarantine if she declined to be tested, Ms. Maxwell was ordered to remove her COVID-protection mask for an in-mouth inspection, further risking exposure to the virus; that Ms. Maxwell was initially quarantined without soap or a toothbrush; that medical and psychology staff, who checked on Ms. Maxwell daily pre-quarantine, have ceased doing so daily since quarantine and have neither informed her of results of the COVID tests nor provided information in response to her inquiry regarding what she should do if she becomes symptomatic.\nThe letter omits the fact that while staff are not supposed to enter Ms. Maxwell's isolation cell during quarantine, an unidentified man entered to take photographs and a guard entered to search. Further, while counsel assumed that an in-person legal visit scheduled for Saturday, November 21, would be canceled as a result of Ms. Maxwell's quarantine status, no notification was provided; and a request for a substituted legal call was not accommodated.\nDOJ-OGR-00001837",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 75 Filed 11/24/20 Page 1 of 2",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "LAW OFFICES OF BOBBI C. STERNHEIM",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "212-243-1100 • Main\n917-306-6666 • Cell\n888-587-4737 • Fax",
      "position": "left margin"
    },
    {
      "type": "printed",
      "content": "33 West 19th Street - 4th Floor\nNew York, New York 10011\nbc@sternheimlaw.com",
      "position": "right margin"
    },
    {
      "type": "printed",
      "content": "November 24, 2020",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Honorable Alison J. Nathan\nUnited States District Judge\nUnited States Courthouse\n40 Foley Square\nNew York, NY 10007",
      "position": "left"
    },
    {
      "type": "printed",
      "content": "Re: United States v. Ghislaine Maxwell\n20 Cr. 330 (AJN)",
      "position": "center"
    },
    {
      "type": "printed",
      "content": "Dear Judge Nathan:",
      "position": "left"
    },
    {
      "type": "printed",
      "content": "As counsel for Ghislaine Maxwell, I write in response to the government's letter, dated November 23, 2020 (see Dkt 74), reporting Ms. Maxwell's conditions of detention and confirming that she is currently in quarantine due to contact with a staff member, assigned to her isolation pod, who tested positive for COVID-19.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "The government recites a variety of allowances given Ms. Maxwell, including being permitted out of her cell three times a week during quarantine for a maximum of 30 minutes, the total time allotted for showering, making personal calls, and using the CorrLinks email system to communicate with family and counsel. However, the letter presents an incomplete picture of Ms. Maxwell's conditions of confinement.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "The government fails to mention a variety of issues brought to the attention of the MDC, including but not limited to the fact: that all email correspondence between Ms. Maxwell and counsel was deleted in advance of the 180-day period, when deletion is expected to occur; that after being administered two nasal swab tests, under threat of 21-day quarantine if she declined to be tested, Ms. Maxwell was ordered to remove her COVID-protection mask for an in-mouth inspection, further risking exposure to the virus; that Ms. Maxwell was initially quarantined without soap or a toothbrush; that medical and psychology staff, who checked on Ms. Maxwell daily pre-quarantine, have ceased doing so daily since quarantine and have neither informed her of results of the COVID tests nor provided information in response to her inquiry regarding what she should do if she becomes symptomatic.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "The letter omits the fact that while staff are not supposed to enter Ms. Maxwell's isolation cell during quarantine, an unidentified man entered to take photographs and a guard entered to search. Further, while counsel assumed that an in-person legal visit scheduled for Saturday, November 21, would be canceled as a result of Ms. Maxwell's quarantine status, no notification was provided; and a request for a substituted legal call was not accommodated.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00001837",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Ghislaine Maxwell",
      "Alison J. Nathan",
      "Bobbi C. Sternheim"
    ],
    "organizations": [
      "LAW OFFICES OF BOBBI C. STERNHEIM",
      "United States Courthouse",
      "MDC"
    ],
    "locations": [
      "New York",
      "United States"
    ],
    "dates": [
      "November 24, 2020",
      "November 23, 2020",
      "November 21, 2020"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "20 Cr. 330 (AJN)",
      "Dkt 74",
      "DOJ-OGR-00001837"
    ]
  },
  "additional_notes": "The document appears to be a formal letter from a lawyer to a judge regarding the conditions of detention of Ghislaine Maxwell. The letter is typed and printed on letterhead. There are no visible redactions or damage."
}