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"full_text": "LAW OFFICES OF BOBBI C. STERNHEIM\n212-243-1100 · Main\n917-912-9698 · Cell\n888-587-4737 · Fax\n225 Broadway, Suite 715\nNew York, NY 10007\nbcsternheim@mac.com\n\nJune 25, 2022\n\nHonorable Alison J. Nathan\nSitting By Designation\nUnited States District Court\n40 Foley Square\nNew York, NY 10010\n\nRe: United States v. Ghislaine Maxwell\nS2 20 Cr. 330 (AJN)\n\nDear Judge Nathan:\n\nI write to inform the Court of a recent development which may require postponement of Tuesday's sentencing proceeding. Yesterday, without having conducted a psychological evaluation and without justification, the MDC placed Ms. Maxwell on suicide watch. She is not permitted to possess and review legal documents and is not permitted paper or pen. This has prevented her from preparing for sentencing.\n\nMs. Maxwell was abruptly removed from general population and returned to solitary confinement, this time without any clothing, toothpaste, soap, legal papers, etc. She was provided a \"suicide smock\" and is given a few sheets of toilet paper on request. This morning, a psychologist evaluated Ms. Maxwell and determined she is not suicidal.\n\nI met with Ms. Maxwell today (after a 97-minute delay following my arrival at the facility). She is not suicidal. Currently, she is unable to properly prepare for sentencing. If Ms. Maxwell remains on suicide watch, is prohibited from reviewing legal materials prior to sentencing, becomes sleep deprived, and is denied sufficient time to meet with and confer with counsel, we will be formally moving on Monday for an adjournment.\n\nVery truly yours,\n\n/s/\nBOBBI C. STERNHEIM\n\ncc: Counsel of Record\n\nDOJ-OGR-00010726",
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"content": "LAW OFFICES OF BOBBI C. STERNHEIM",
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"content": "212-243-1100 · Main\n917-912-9698 · Cell\n888-587-4737 · Fax\n225 Broadway, Suite 715\nNew York, NY 10007\nbcsternheim@mac.com",
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{
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"type": "printed",
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"content": "June 25, 2022",
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{
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"type": "printed",
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"content": "Honorable Alison J. Nathan\nSitting By Designation\nUnited States District Court\n40 Foley Square\nNew York, NY 10010",
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"content": "Re: United States v. Ghislaine Maxwell\nS2 20 Cr. 330 (AJN)",
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"type": "printed",
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"content": "Dear Judge Nathan:",
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{
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"type": "printed",
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"content": "I write to inform the Court of a recent development which may require postponement of Tuesday's sentencing proceeding. Yesterday, without having conducted a psychological evaluation and without justification, the MDC placed Ms. Maxwell on suicide watch. She is not permitted to possess and review legal documents and is not permitted paper or pen. This has prevented her from preparing for sentencing.",
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"position": "middle"
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},
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"type": "printed",
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"content": "Ms. Maxwell was abruptly removed from general population and returned to solitary confinement, this time without any clothing, toothpaste, soap, legal papers, etc. She was provided a \"suicide smock\" and is given a few sheets of toilet paper on request. This morning, a psychologist evaluated Ms. Maxwell and determined she is not suicidal.",
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"position": "middle"
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},
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{
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"type": "printed",
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"content": "I met with Ms. Maxwell today (after a 97-minute delay following my arrival at the facility). She is not suicidal. Currently, she is unable to properly prepare for sentencing. If Ms. Maxwell remains on suicide watch, is prohibited from reviewing legal materials prior to sentencing, becomes sleep deprived, and is denied sufficient time to meet with and confer with counsel, we will be formally moving on Monday for an adjournment.",
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"position": "middle"
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{
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"type": "printed",
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"content": "Very truly yours,",
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"position": "bottom"
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},
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{
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"type": "signature",
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"content": "/s/\nBOBBI C. STERNHEIM",
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"position": "bottom"
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},
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{
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"type": "printed",
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"content": "cc: Counsel of Record",
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{
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"type": "printed",
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"content": "DOJ-OGR-00010726",
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"position": "footer"
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],
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"entities": {
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"people": [
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"Alison J. Nathan",
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"Ghislaine Maxwell",
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"Bobbi C. Sternheim"
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],
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"organizations": [
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"United States District Court",
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"MDC"
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],
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"locations": [
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"New York"
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],
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"dates": [
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"June 25, 2022",
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"Monday"
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],
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"reference_numbers": [
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"S2 20 Cr. 330 (AJN)",
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"DOJ-OGR-00010726"
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]
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},
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"additional_notes": "The document appears to be a formal letter from Bobbi C. Sternheim to Judge Alison J. Nathan regarding the case of Ghislaine Maxwell. The letter discusses Maxwell's recent placement on suicide watch and its impact on her ability to prepare for sentencing. The document is well-formatted and free of significant damage or redactions."
"full_text": "Case 1:20-cr-00330-PAE Document 679 Filed 06/26/22 Page 1 of 4 U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 June 26, 2022 By ECF The Honorable Alison J. Nathan, Sitting by Designation United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, S2 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully submits this letter in response to the Court's June 25, 2022 Order directing the Government to confer with the Warden of the Metropolitan Detention Center (\"MDC\") regarding the defendant's access to legal materials and counsel.1 This morning, the Government spoke directly with the Warden and the Chief Psychologist of the MDC. Based on that conversation, the Government understands that the defendant currently has access to all of her legal documents in hard copy and is able to confer with defense counsel. Accordingly, there is no basis to adjourn sentencing in this matter. 1 The Government first learned of the defendant's newly raised concerns about her conditions of confinement through the publicly filed letter from defense counsel last night. (Dkt. No. 677). Defense counsel did not confer with or seek assistance directly from the Government before filing that letter. 1 DOJ-OGR-00010729",
"content": "U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 June 26, 2022",
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},
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{
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"type": "printed",
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"content": "By ECF The Honorable Alison J. Nathan, Sitting by Designation United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, S2 20 Cr. 330 (AJN)",
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"position": "middle"
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},
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{
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"type": "printed",
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"content": "Dear Judge Nathan: The Government respectfully submits this letter in response to the Court's June 25, 2022 Order directing the Government to confer with the Warden of the Metropolitan Detention Center (\"MDC\") regarding the defendant's access to legal materials and counsel.1 This morning, the Government spoke directly with the Warden and the Chief Psychologist of the MDC. Based on that conversation, the Government understands that the defendant currently has access to all of her legal documents in hard copy and is able to confer with defense counsel. Accordingly, there is no basis to adjourn sentencing in this matter.",
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"position": "middle"
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},
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{
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"type": "printed",
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"content": "1 The Government first learned of the defendant's newly raised concerns about her conditions of confinement through the publicly filed letter from defense counsel last night. (Dkt. No. 677). Defense counsel did not confer with or seek assistance directly from the Government before filing that letter.",
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"position": "bottom"
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{
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"type": "printed",
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"content": "1 DOJ-OGR-00010729",
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"position": "footer"
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},
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{
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"type": "stamp",
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"content": "",
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"position": "left margin"
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}
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],
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"entities": {
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"people": [
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"Alison J. Nathan",
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"Ghislaine Maxwell"
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],
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"organizations": [
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"U.S. Department of Justice",
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"United States Attorney",
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"Metropolitan Detention Center"
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],
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"locations": [
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"New York",
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"Southern District of New York"
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],
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"dates": [
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"June 26, 2022",
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"June 25, 2022"
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],
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"reference_numbers": [
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"1:20-cr-00330-PAE",
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"Document 679",
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"S2 20 Cr. 330 (AJN)",
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"Dkt. No. 677",
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"DOJ-OGR-00010729"
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]
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},
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"additional_notes": "The document is a letter from the U.S. Department of Justice to the Honorable Alison J. Nathan regarding the case United States v. Ghislaine Maxwell. The letter is dated June 26, 2022, and is in response to a court order from June 25, 2022. The document contains a stamp on the left margin."
"full_text": "Case 1:20-cr-00330-PAE Document 679 Filed 06/26/22 Page 2 of 4\n\nBased on information provided by the Warden and the Chief Psychologist of the MDC this morning, the Government understands the following regarding the defendant's current status and conditions at the MDC. On Friday, June 24, 2022, the Warden of the MDC was informed that the Bureau of Prisons Inspector General's Office (the \"IG\") had received an email directly from the defendant from within the MDC claiming to be in fear for her safety. Apparently the defendant claimed to the IG that she feared MDC staff members were threatening her safety. The Warden and the Chief of Psychology felt obligated to remove the defendant from general population and investigate the defendant's claim. Ordinarily, an inmate raising such a safety concern would be placed in a single cell of the Special Housing Unit (\"SHU\") of the MDC. In circumstances where the facility is concerned that the inmate is at heightened risk of self-harm, however, the MDC will instead place the inmate on suicide watch. The Warden and Chief Psychologist indicated that at least two other inmates have recently been placed on suicide watch in similar circumstances.\n\nHere, the Warden and Chief Psychologist assessed that the defendant is at heightened risk of self-harm, particularly given her upcoming sentencing and sex offender status. As a result, they are not comfortable placing the defendant in the SHU, but they also need to remove the defendant from general population to investigate the threat she reported to the IG. Accordingly, the defendant was placed on suicide watch. Although the defendant has claimed to psychology staff that she is not suicidal, she has refused to answer psychology staff's questions regarding the threat she reported to the IG. While she claimed to the IG to be in fear for her safety, she refused to tell psychology staff what that fear is. Given the defendant's inconsistent accounts to the IG and to psychology staff, the Chief Psychologist assesses the defendant to be at additional risk of self-harm, as it appears she may be attempting to be transferred to a single cell where she can engage\n\n2\n\nDOJ-OGR-00010730",
"content": "Based on information provided by the Warden and the Chief Psychologist of the MDC this morning, the Government understands the following regarding the defendant's current status and conditions at the MDC. On Friday, June 24, 2022, the Warden of the MDC was informed that the Bureau of Prisons Inspector General's Office (the \"IG\") had received an email directly from the defendant from within the MDC claiming to be in fear for her safety. Apparently the defendant claimed to the IG that she feared MDC staff members were threatening her safety. The Warden and the Chief of Psychology felt obligated to remove the defendant from general population and investigate the defendant's claim. Ordinarily, an inmate raising such a safety concern would be placed in a single cell of the Special Housing Unit (\"SHU\") of the MDC. In circumstances where the facility is concerned that the inmate is at heightened risk of self-harm, however, the MDC will instead place the inmate on suicide watch. The Warden and Chief Psychologist indicated that at least two other inmates have recently been placed on suicide watch in similar circumstances.",
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"position": "top"
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},
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{
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"type": "printed",
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"content": "Here, the Warden and Chief Psychologist assessed that the defendant is at heightened risk of self-harm, particularly given her upcoming sentencing and sex offender status. As a result, they are not comfortable placing the defendant in the SHU, but they also need to remove the defendant from general population to investigate the threat she reported to the IG. Accordingly, the defendant was placed on suicide watch. Although the defendant has claimed to psychology staff that she is not suicidal, she has refused to answer psychology staff's questions regarding the threat she reported to the IG. While she claimed to the IG to be in fear for her safety, she refused to tell psychology staff what that fear is. Given the defendant's inconsistent accounts to the IG and to psychology staff, the Chief Psychologist assesses the defendant to be at additional risk of self-harm, as it appears she may be attempting to be transferred to a single cell where she can engage",
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"position": "middle"
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{
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"type": "printed",
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"content": "2",
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"position": "footer"
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},
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{
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"type": "printed",
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"content": "DOJ-OGR-00010730",
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"position": "footer"
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}
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],
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"entities": {
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"people": [],
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"organizations": [
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"MDC",
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"Bureau of Prisons Inspector General's Office",
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"IG"
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],
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"locations": [],
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+
"dates": [
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"June 24, 2022",
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"06/26/22"
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],
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"reference_numbers": [
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"1:20-cr-00330-PAE",
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"679",
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"DOJ-OGR-00010730"
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]
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},
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"additional_notes": "The document appears to be a court filing related to the defendant's status and conditions at the MDC. The text is printed and there are no visible stamps or handwritten notes. The document is page 2 of 4."
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