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833 KB
Extraction Summary
3
People
5
Organizations
3
Locations
2
Events
2
Relationships
6
Quotes
Document Information
Type:
Legal document
File Size:
833 KB
Summary
This legal letter, sent from attorney Bobbi C. Sternheim to Judge Alison J. Nathan, protests the detention conditions of her client, Ghislaine Maxwell, at the MDC. The letter argues that the 15-minute flashlight checks are disruptive and based on spurious justifications, such as 'enhanced security'. Sternheim refutes the government's claim that Maxwell possesses a contraband eye mask and provides evidence from an intake form showing Maxwell did not express safety concerns about being in the general population, contradicting the MDC's assertions.
People (3)
| Name | Role | Context |
|---|---|---|
| Bobbi C. Sternheim | Attorney |
The letter is from the Law Offices of Bobbi C. Sternheim, presumably written by her as counsel for Ghislaine Maxwell.
|
| Alison J. Nathan | Honorable Judge |
The recipient of the letter, a judge for the United States District Court.
|
| Ghislaine Maxwell | Defendant |
The subject of the letter and the case United States v. Ghislaine Maxwell. The letter discusses the conditions of her...
|
Organizations (5)
| Name | Type | Context |
|---|---|---|
| LAW OFFICES OF BOBBI C. STERNHEIM | Law firm |
The sender of the letter, as indicated by the letterhead.
|
| United States District Court | Government agency |
The court where Judge Alison J. Nathan presides and to which the letter is addressed.
|
| MDC | Detention facility |
The detention center where Ms. Maxwell is being held. Its security procedures and claims are the main subject of the ...
|
| Second Circuit | Court |
Mentioned in the context of hearing Ms. Maxwell's bail appeal.
|
| United States | Government |
The prosecuting party in the case 'United States v. Ghislaine Maxwell'.
|
Timeline (2 events)
2020-07-06
Oral argument of Ms. Maxwell’s bail appeal.
Second Circuit
Ghislaine Maxwell's counsel
Locations (3)
| Location | Context |
|---|---|
|
The address of the Law Offices of Bobbi C. Sternheim.
|
|
|
The address of the United States District Court where Judge Nathan is located.
|
|
|
Location of both the law office and the courthouse.
|
Relationships (2)
The letter identifies Sternheim's law office as representing Maxwell, referring to her as 'Ms. Maxwell's counsel'.
Maxwell is the defendant in a case being heard by Judge Nathan.
Key Quotes (6)
"has an eye mask."Source
— the government
(An allegation from a government report about Ms. Maxwell, which was refuted by her counsel.)
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Quote #1
"an enhanced security schedule."Source
— MDC
(The MDC's justification for the 15-minute flashlight surveillance on Ms. Maxwell.)
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Quote #2
"heightened safety and security concerns"Source
— MDC
(The reasons given by the MDC to support the need for the enhanced security schedule.)
DOJ-OGR-00001438.jpg
Quote #3
"expressed concern for her safety if she were housed in general population."Source
— MDC (claim about Ms. Maxwell)
(A claim made by the MDC, which the letter argues is an attempt to shift focus from its own conduct.)
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Quote #4
"Do you know of any reason why you should not be placed in general population?"Source
— Intake Screening Form
(A question posed to Ms. Maxwell upon her entry to the MDC.)
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Quote #5
"No."Source
— Ghislaine Maxwell
(Ms. Maxwell's response to the question on the Intake Screening Form about being placed in general population.)
DOJ-OGR-00001438.jpg
Quote #6
Full Extracted Text
Complete text extracted from the document (2,411 characters)
Case: 20-cr-00330-AJN Document 272 Filed 05/07/21 Page 1 of 3
LAW OFFICES OF BOBBI C. STERNHEIM
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
May 7, 2020
Honorable Alison J. Nathan
United States District Court
United States Courthouse
40 Foley Square
New York, NY 10007
United States District Court
United States Courthouse
40 Foley Square
New York, NY 10007
Re: United States v. Ghislaine Maxwell
S2 20 Cr. 330 (AJN)
S2 20 Cr. 330 (AJN)
Dear Judge Nathan:
Once again, the government reports second- and third-hand information from the MDC,
the reliability of which becomes increasingly questionable. In its May 5th letter regarding the
MDC’s flashlight security checks of Ms. Maxwell (Dkt. 270), the government contradicts a
previous report that Ms. Maxwell “has an eye mask.” This allegation, immediately refuted by her
counsel, was a focus of the Second Circuit’s questioning during oral argument of Ms. Maxwell’s
bail appeal. Now, the government reports that the MDC cannot provide an eye mask to Ms.
Maxwell and that an eye mask is considered contraband. This alone is a basis for the Court to
question the veracity of representations made by the MDC.
the reliability of which becomes increasingly questionable. In its May 5th letter regarding the
MDC’s flashlight security checks of Ms. Maxwell (Dkt. 270), the government contradicts a
previous report that Ms. Maxwell “has an eye mask.” This allegation, immediately refuted by her
counsel, was a focus of the Second Circuit’s questioning during oral argument of Ms. Maxwell’s
bail appeal. Now, the government reports that the MDC cannot provide an eye mask to Ms.
Maxwell and that an eye mask is considered contraband. This alone is a basis for the Court to
question the veracity of representations made by the MDC.
To justify the 15-minute flashlight surveillance that is causing Ms. Maxwell’s disruptive
sleep and sleep deprivation, the MDC claims that Ms. Maxwell is on “an enhanced security
schedule.” The reasons given to support the need for “heightened safety and security concerns”
with respect to Ms. Maxwell are spurious. They single out Ms. Maxwell to the detriment of
other pretrial detainees who face even more serious charges and potential stress (i.e., defendants
charged with murder and terrorism offenses subjected to life sentences without possibility of
release and the death penalty) and who are incarcerated in cells by themselves. The MDC
attempts to shift the focus of its conduct by claiming that it is responsive to Ms. Maxwell’s
“expressed concern for her safety if she were housed in general population.”
sleep and sleep deprivation, the MDC claims that Ms. Maxwell is on “an enhanced security
schedule.” The reasons given to support the need for “heightened safety and security concerns”
with respect to Ms. Maxwell are spurious. They single out Ms. Maxwell to the detriment of
other pretrial detainees who face even more serious charges and potential stress (i.e., defendants
charged with murder and terrorism offenses subjected to life sentences without possibility of
release and the death penalty) and who are incarcerated in cells by themselves. The MDC
attempts to shift the focus of its conduct by claiming that it is responsive to Ms. Maxwell’s
“expressed concern for her safety if she were housed in general population.”
The MDC should fact check its records before making bold assertions. The Intake
Screening Form completed by Ms. Maxwell upon entry to the MDC on July 6, 2020 posed the
following question: “Do you know of any reason why you should not be placed in general
population?” Ms. Maxwell responded “No.” It is the MDC, not the inmate, who makes the
determination regarding general population or degree of segregation. The Intake Screening
Screening Form completed by Ms. Maxwell upon entry to the MDC on July 6, 2020 posed the
following question: “Do you know of any reason why you should not be placed in general
population?” Ms. Maxwell responded “No.” It is the MDC, not the inmate, who makes the
determination regarding general population or degree of segregation. The Intake Screening
DOJ-OGR-00001438
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