DOJ-OGR-00001866.jpg
927 KB
Extraction Summary
6
People
5
Organizations
4
Locations
4
Events
6
Relationships
2
Quotes
Document Information
Type:
Legal document
File Size:
927 KB
Summary
This legal letter, sent by attorney Bobbi C. Sternheim on behalf of her client Ghislaine Maxwell to Judge Alison J. Nathan, formally complains about Maxwell's harsh and restrictive conditions at the Metropolitan Detention Center (MDC). The letter refutes a previous communication from MDC staff, detailing issues such as significant weight loss, isolation, constant surveillance, and a recent quarantine that hindered her defense preparation. Sternheim renews the request for the MDC Warden, Heriberto Tellez, to respond directly to the Court and justify these conditions.
People (6)
| Name | Role | Context |
|---|---|---|
| Bobbi C. Sternheim | Attorney |
The letter is from the Law Offices of Bobbi C. Sternheim, who is identified as counsel for Ghislaine Maxwell.
|
| Alison J. Nathan | Honorable United States District Judge |
The recipient of the letter.
|
| Ghislaine Maxwell | Defendant/Client |
The subject of the letter, whose conditions of confinement are being discussed. Referred to as Ms. Maxwell.
|
| Sophia Papapetru | MDC staff attorney |
Co-author of a previous letter from the MDC to which this letter is a response.
|
| John Wallace | MDC staff attorney |
Co-author of a previous letter from the MDC to which this letter is a response.
|
| Heriberto Tellez | Warden |
The Warden of the MDC, to whom a previous letter was sent and from whom a direct response is requested.
|
Organizations (5)
| Name | Type | Context |
|---|---|---|
| LAW OFFICES OF BOBBI C. STERNHEIM | Law firm |
The sender of the letter.
|
| United States District Judge | Government agency |
The title of the letter's recipient, Alison J. Nathan.
|
| United States Courthouse | Government facility |
The location of Judge Nathan's office.
|
| MDC | Correctional facility |
The Metropolitan Detention Center where Ghislaine Maxwell is being held.
|
| BOP | Government agency |
Bureau of Prisons, mentioned in relation to policy for inmate meals.
|
Timeline (4 events)
Ongoing as of 2020-12-07
Ongoing as of 2020-12-07
Ghislaine Maxwell is kept in isolation and not permitted to participate in general population activities like programming, movies, religious services, or job assignments.
MDC
prior to 2020-12-07
Ghislaine Maxwell lost over 15 pounds and is sustaining hair loss while detained at the MDC.
MDC
prior to 2020-12-07
Ghislaine Maxwell was quarantined for 14 days after being in contact with a member of her security team who tested positive for COVID-19, which resulted in cancelled legal visits.
MDC
Ghislaine Maxwell
unnamed security team member
Locations (4)
| Location | Context |
|---|---|
|
The address of the Law Offices of Bobbi C. Sternheim.
|
|
|
Location of the law office and courthouse.
|
|
|
The address of the United States Courthouse where Judge Nathan is located.
|
|
|
The facility where Ms. Maxwell arrived and is being detained.
|
Relationships (6)
The letter begins, 'As counsel for Ghislaine Maxwell...'
Sternheim, an attorney, is writing to Judge Nathan, who is presiding over her client's case.
The letter concerns the case 'United States v. Ghislaine Maxwell' over which Judge Nathan is presiding.
Tellez is the Warden of the MDC where Maxwell is detained, and the letter requests he respond to the court about her conditions.
Sternheim's letter is written in direct response to and refutation of a letter co-authored by Papapetru, an MDC staff attorney.
Sternheim's letter is written in direct response to and refutation of a letter co-authored by Wallace, an MDC staff attorney.
Key Quotes (2)
"[i]n her current assignment,"Source
— Letter from Sophia Papapetru and John Wallace
(Used by the MDC's letter to describe Ms. Maxwell's situation, which her counsel argues is an attempt to present a picture of compliance while disregarding past and ongoing deficiencies in her treatment.)
DOJ-OGR-00001866.jpg
Quote #1
"a number of inmates who have tested positive for COVID-19,"Source
— Letter from Sophia Papapetru and John Wallace
(A claim from the MDC's letter that Ms. Maxwell is not in contact with COVID-positive inmates, which her counsel argues ignores her contact with a security team member who tested positive.)
DOJ-OGR-00001866.jpg
Quote #2
Full Extracted Text
Complete text extracted from the document (2,849 characters)
Case 1:20-cr-00330-AJN Document 91 Filed 12/07/20 Page 1 of 10
LAW OFFICES OF BOBBI C. STERNHEIM
212-243-1100 • Main
917-306-6666 • Cell
888-587-4737 • Fax
917-306-6666 • Cell
888-587-4737 • Fax
33 West 19th Street - 4th Floor
New York, New York 10011
bc@sternheimlaw.com
New York, New York 10011
bc@sternheimlaw.com
December 7, 2020
BY ECF
Honorable Alison J. Nathan
United States District Judge
United States Courthouse
40 Foley Square
New York, NY 10007
United States District Judge
United States Courthouse
40 Foley Square
New York, NY 10007
Re: United States v. Ghislaine Maxwell
20 Cr. 330 (AJN)
20 Cr. 330 (AJN)
Dear Judge Nathan:
As counsel for Ghislaine Maxwell, we write in response to the letter from Sophia Papapetru and John Wallace, MDC staff attorneys. (See Dkt. 88.) The letter fails to address a number of concerns raised in our October 29th letter to Warden Heriberto Tellez and raised with the Court. The MDC’s letter also contains inaccuracies and omissions and raises more questions than it attempts to answer. Rather than paraphrase our letter, we are providing it for the Court’s consideration. (See Exhibit A.) We renew our request that Warden Tellez respond directly to the Court and counsel and explain why Ms. Maxwell must be detained under such harsh and restrictive conditions.
Using the term “[i]n her current assignment,” the letter attempts to present a picture of compliance with total disregard of the deficiencies of Ms. Maxwell’s treatment up to this point. While her meals may currently be in accordance with BOP policy, until September they were not. While her weight may currently be fairly consistent, she had lost over 15 pounds, and she is sustaining hair loss. It took approximately six weeks following arrival to the MDC for Ms. Maxwell to be permitted personal calls on par with other inmates; previously she was given two calls per month unless authorized by the warden. While generally permitted to be out of her isolation cell and confined to the day room from 7:00 am to 8:00 pm with one hour of recreation time, general population inmates are permitted to be out of their cells until 9:30 pm and given more extensive recreation time. While flashlight checks may be performed during regular rounds, Ms. Maxwell is subject to such checks every 15 minutes. Further, because Ms. Maxwell is kept in isolation, she in not permitted to participate in activities accorded inmates in general population, such as programming (educational, leisure and wellness), movies, religious services, job assignment.
Touting that Ms. Maxwell is not in contact with “a number of inmates who have tested positive for COVID-19,” the MDC’s letter totally ignores that she was in contact with a member of her revolving security team who tested positive, necessitating that Ms. Maxwell be quarantined for 14 days. This further diminished her ability to prepare her defense and resulted in cancelled legal visits. While the letter accurately states that one video teleconference (VTC) was
DOJ-OGR-00001866
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