mirror-epstein-docs/results/IMAGES001/DOJ-OGR-00001835.json

{
  "document_metadata": {
    "page_number": "1",
    "document_number": "74",
    "date": "11/23/20",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 74 Filed 11/23/20 Page 1 of 2\nU.S. Department of Justice\nUnited States Attorney\nSouthern District of New York\nThe Silvio J. Mollo Building\nOne Saint Andrew's Plaza\nNew York, New York 10007\nNovember 23, 2020\nBY ECF\nThe Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\nUnited States Courthouse\n40 Foley Square\nNew York, New York 10007\nRe: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)\nDear Judge Nathan:\nThe Government respectfully submits this letter to provide an update regarding the defendant's conditions of confinement at the Metropolitan Detention Center (\"MDC\") pursuant to the Court's Order dated August 25, 2020. (Dkt. No. 49). Over the past three months, the Government has had multiple conversations with MDC legal counsel regarding the defendant's conditions of confinement. This update is based on information provided to the Government by MDC legal during those conversations.\nLast week, a staff member who was assigned to work in the area of the MDC where the defendant is housed tested positive for COVID-19. In response, the MDC implemented the same quarantine protocols that apply whenever an inmate has potentially been exposed to the virus. Specifically, on November 18, 2020, the defendant was tested for COVID-19 using a rapid test, which was negative. That same day, the defendant was placed in quarantine. As with any other quarantined inmate, the defendant will remain in quarantine for fourteen days, at which point she will be tested again for COVID-19. If that test is negative, she will then be released from quarantine. To date, the defendant has not exhibited any symptoms of COVID-19.\nDuring her time in quarantine, the defendant will be housed in the same cell where she was already housed before she was placed in quarantine, and medical staff and psychology staff will continue to check on the defendant every day. Like all other MDC inmates in quarantine, the defendant will be permitted out of her cell three days per week for thirty minutes. During that time, the defendant may shower, make personal phone calls, and use the CorrLinks email system. In addition, the defendant will continue to be permitted to make legal calls every day for up to three hours per day. These calls will take place in a room where the defendant is alone and where no MDC staff can hear her communications with counsel.\nOn November 18, 2020, the Government provided the MDC with a laptop for the defendant to use to review discovery. During quarantine, the defendant has been and will continue to be permitted to use that laptop in her isolation cell to review her discovery for thirteen hours per day,\nDOJ-OGR-00001835",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 74 Filed 11/23/20 Page 1 of 2",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "U.S. Department of Justice\nUnited States Attorney\nSouthern District of New York\nThe Silvio J. Mollo Building\nOne Saint Andrew's Plaza\nNew York, New York 10007",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "November 23, 2020",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "BY ECF",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\nUnited States Courthouse\n40 Foley Square\nNew York, New York 10007",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Dear Judge Nathan:",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The Government respectfully submits this letter to provide an update regarding the defendant's conditions of confinement at the Metropolitan Detention Center (\"MDC\") pursuant to the Court's Order dated August 25, 2020. (Dkt. No. 49). Over the past three months, the Government has had multiple conversations with MDC legal counsel regarding the defendant's conditions of confinement. This update is based on information provided to the Government by MDC legal during those conversations.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Last week, a staff member who was assigned to work in the area of the MDC where the defendant is housed tested positive for COVID-19. In response, the MDC implemented the same quarantine protocols that apply whenever an inmate has potentially been exposed to the virus. Specifically, on November 18, 2020, the defendant was tested for COVID-19 using a rapid test, which was negative. That same day, the defendant was placed in quarantine. As with any other quarantined inmate, the defendant will remain in quarantine for fourteen days, at which point she will be tested again for COVID-19. If that test is negative, she will then be released from quarantine. To date, the defendant has not exhibited any symptoms of COVID-19.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "During her time in quarantine, the defendant will be housed in the same cell where she was already housed before she was placed in quarantine, and medical staff and psychology staff will continue to check on the defendant every day. Like all other MDC inmates in quarantine, the defendant will be permitted out of her cell three days per week for thirty minutes. During that time, the defendant may shower, make personal phone calls, and use the CorrLinks email system. In addition, the defendant will continue to be permitted to make legal calls every day for up to three hours per day. These calls will take place in a room where the defendant is alone and where no MDC staff can hear her communications with counsel.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "On November 18, 2020, the Government provided the MDC with a laptop for the defendant to use to review discovery. During quarantine, the defendant has been and will continue to be permitted to use that laptop in her isolation cell to review her discovery for thirteen hours per day,",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00001835",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ghislaine Maxwell"
    ],
    "organizations": [
      "U.S. Department of Justice",
      "United States Attorney",
      "Southern District of New York",
      "Metropolitan Detention Center"
    ],
    "locations": [
      "New York",
      "United States Courthouse",
      "Foley Square"
    ],
    "dates": [
      "November 23, 2020",
      "August 25, 2020",
      "November 18, 2020"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "Document 74",
      "20 Cr. 330 (AJN)",
      "Dkt. No. 49",
      "DOJ-OGR-00001835"
    ]
  },
  "additional_notes": "The document appears to be a formal letter from the U.S. Department of Justice to the Honorable Alison J. Nathan regarding the conditions of confinement of Ghislaine Maxwell at the Metropolitan Detention Center. The document is typed and does not contain any handwritten text or stamps."
}