DOJ-OGR-00001139.jpg
538 KB
Extraction Summary
2
People
4
Organizations
1
Locations
4
Events
1
Relationships
1
Quotes
Document Information
Type:
Legal document
File Size:
538 KB
Summary
This legal document outlines two major impediments to Ms. Maxwell's defense preparation. Firstly, it details persistent technical failures with discovery materials provided by the government, including broken and malfunctioning hard drives, which have left her without access to readable evidence for over four months. Secondly, it describes the added burdens of a 14-day COVID-19 quarantine and heightened exposure risk at the MDC due to contact with untested staff, further limiting her ability to review case materials and prepare for trial.
People (2)
| Name | Role | Context |
|---|---|---|
| Ms. Maxwell | Defendant |
The central subject of the document, facing issues with discovery materials and quarantine conditions while detained.
|
| associate warden | Prison official |
Reported to the Criminal Justice Advisory Board that the MDC does not mandate COVID testing for staff.
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| government | Government entity |
The opposing party in the legal case, responsible for providing discovery productions to the defense.
|
| BOP | Government agency |
Mentioned as the source of some guards assigned to Ms. Maxwell, from institutions with their own COVID outbreaks.
|
| Criminal Justice Advisory Board | Advisory board |
Received a report from the associate warden regarding MDC's COVID testing policy.
|
| MDC | Correctional facility |
The facility where Ms. Maxwell is detained. Mentioned as not mandating COVID testing for staff and where Ms. Maxwell ...
|
Timeline (4 events)
2020-08-27
The defense alerted the government that significant portions of the first three discovery productions were unreadable.
defense
government
2020-11-18
Ms. Maxwell was given a COVID test and placed in a 14-day quarantine after contact with a staffer who tested positive.
MDC
Ms. Maxwell
staffer
2020-11-18
The government provided a laptop computer to Ms. Maxwell in the MDC at the request of the defense.
MDC
2020-12-02
The associate warden reported to the Criminal Justice Advisory Board that MDC does not mandate COVID testing for its staff.
MDC
Locations (1)
| Location | Context |
|---|---|
|
The location where Ms. Maxwell is being held and experiencing issues with discovery and quarantine.
|
Relationships (1)
The document describes the defense, on behalf of Ms. Maxwell, repeatedly alerting the government about its failure to provide readable discovery materials, which are essential for her legal defense.
Key Quotes (1)
"Ms. Maxwell cannot defend herself if she cannot review the discovery."Source
— Author of the document (defense)
(This statement concludes the section detailing the persistent technical failures of the discovery materials provided by the government, arguing that this failure prevents a proper defense.)
DOJ-OGR-00001139.jpg
Quote #1
Full Extracted Text
Complete text extracted from the document (2,407 characters)
Case 20-cr-00330-AJN Document 192 Filed 12/04/20 Page 48 of 205
alerted the government on August 27, 2020 that there were significant portions of the first three discovery productions that Ms. Maxwell could not read. (Dkt. 66). Despite numerous attempts to fix these problems over the succeeding weeks, including producing a replacement hard drive containing these productions, the problems were not resolved and the replacement hard drive was broken. In addition, the fourth and fifth productions, which were produced after the defense alerted the government to these problems, contained some of the same technical problems and included a significant number of unreadable documents. Most recently, the hard drives for the sixth and seventh productions have stopped functioning properly. As a result, Ms. Maxwell has not had access to a complete set of readable discovery for over four months.13 Ms. Maxwell cannot defend herself if she cannot review the discovery.
Most recently, Ms. Maxwell has had to endure the added burdens of quarantine. On November 18, 2020, Ms. Maxwell was given a COVID test and placed in 14-day quarantine due to contact with a staffer who tested positive. The revolving team of guards assigned to Ms. Maxwell, some coming from other BOP institutions confronting their own COVID outbreaks, heightens her exposure to the virus. As reported by the associate warden to the Criminal Justice Advisory Board on December 2, MDC does not mandate testing among its staff. A temperature check and response to a few questions does little to detect an asymptomatic carrier. The constant strip searching, touch wanding, and in-mouth checking of Ms. Maxwell heightens her risk for exposure to COVID-19.
13 On November 18, 2020, the government, at our request, provided a laptop computer to Ms. Maxwell in the MDC, which it believed would remedy the issues with unreadable documents, and has agreed to provide a new hard drive containing all of the discovery. It is too early to tell whether the new laptop and hard drive will solve all of the technical problems. We note, however, that now that Ms. Maxwell has been released from quarantine, she only has access to the laptop from 8am-5pm, five days a week, which will effectively limit her review time to that time slot because of compatibility issues between the recently produced hard drives and the prison computer.
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DOJ-OGR-00001139
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