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684 KB
Extraction Summary
3
People
6
Organizations
2
Locations
3
Events
1
Relationships
4
Quotes
Document Information
Type:
Legal filing / attorney letter
File Size:
684 KB
Summary
This document is a page from a legal filing by attorney Bobbi C. Sternheim regarding the confinement conditions of Ghislaine Maxwell. It details grievances including the persistence of mail delays (specifically a FedEx package with a discovery disc), the serving of moldy food, sleep deprivation due to constant lighting and flashlight checks, and the deletion of legal emails via CorrLinks. The filing argues that Maxwell is in 'de facto solitary confinement' and lacks adequate computer resources to review discovery for her trial.
People (3)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant/Inmate |
Subject of the letter describing poor conditions of confinement.
|
| Bobbi C. Sternheim | Defense Attorney |
Author of the letter representing Ms. Maxwell.
|
| Guards | Prison Staff |
Accused of over-managing Maxwell and disturbing sleep with flashlights.
|
Organizations (6)
| Name | Type | Context |
|---|---|---|
| Law Offices of Bobbi C. Sternheim | ||
| MDC |
Metropolitan Detention Center (implied), accused of violating policy.
|
|
| Federal Express |
Delivery of legal mail delayed.
|
|
| New York Times |
Old issue received by inmate.
|
|
| CorrLinks |
Email system used by inmates.
|
|
| The Government |
Sent discovery disc.
|
Timeline (3 events)
Mid-March 2021
Ongoing
Guards point flashlights into cell every 15 minutes during the night.
Detention Facility
Week of 2021-04-07
Locations (2)
| Location | Context |
|---|---|
|
Detention facility where Maxwell is held (implied by context of confinement).
|
|
|
Location of sleep deprivation and surveillance.
|
Relationships (1)
Header: Law Offices of Bobbi C. Sternheim; Content advocates for Maxwell.
Key Quotes (4)
"the MDC violated its own policy by prematurely deleting Ms. Maxwell’s legal emails."Source
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Quote #1
"she was given a salad containing mold earlier this week."Source
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Quote #2
"She covers her eyes with a towel to shield them from glaring overhead lighting that she cannot turn off"Source
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Quote #3
"she remains in de facto solitary confinement, over-managed by multiple guards, and surveilled by multiple cameras 24 hours per day."Source
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Quote #4
Full Extracted Text
Complete text extracted from the document (1,956 characters)
Case 1:20-cr-00330-AJN Document 297-1 Filed 04/07/21 Page 4 of 5
LAW OFFICES OF BOBBI C. STERNHEIM
LAW OFFICES OF BOBBI C. STERNHEIM
taken seriously,” and just like the majority of complaints filed by inmates, the facility refuses to
provide results of this and other inquiries.
provide results of this and other inquiries.
The mail and food issues persist. Even a Federal Express envelope from the government
was not given to Ms. Maxwell until two weeks after it was sent, containing a discovery disc that
was unreadable. In mid-March, she received a copy of the New York Times issued in October.
Any claim that Ms. Maxwell deletes CorrLinks emails, which is disputed, does little to erase the
fact that the MDC violated its own policy by prematurely deleting Ms. Maxwell’s legal emails.
That her food is not heated in a thermal oven does little to explain why she was given a salad
containing mold earlier this week.
was not given to Ms. Maxwell until two weeks after it was sent, containing a discovery disc that
was unreadable. In mid-March, she received a copy of the New York Times issued in October.
Any claim that Ms. Maxwell deletes CorrLinks emails, which is disputed, does little to erase the
fact that the MDC violated its own policy by prematurely deleting Ms. Maxwell’s legal emails.
That her food is not heated in a thermal oven does little to explain why she was given a salad
containing mold earlier this week.
Ms. Maxwell does not have an eye mask; she’s not even provided a suitable face mask.
She covers her eyes with a towel to shield them from glaring overhead lighting that she cannot
turn off and from flashlights pointed into her cell every 15 minutes during the night. That Ms.
Maxwell chooses not to respond to guards during the nighttime is no indication that she is
engaged in restful sleep; rather, it’s a respite from having to engage with them.
She covers her eyes with a towel to shield them from glaring overhead lighting that she cannot
turn off and from flashlights pointed into her cell every 15 minutes during the night. That Ms.
Maxwell chooses not to respond to guards during the nighttime is no indication that she is
engaged in restful sleep; rather, it’s a respite from having to engage with them.
No amount of gloss put on Ms. Maxwell’s conditions of confinement can erase the fact
that she remains in de facto solitary confinement, over-managed by multiple guards, and
surveilled by multiple cameras 24 hours per day. The computer equipment provided remains
inadequate to review the millions of pages of discovery under circumstances that are not
conducive to preparing for trial. It is unreasonable to believe that not being able to search, mark,
save, and print is sufficient to prepare this document-laden case for trial. The Court need only
imagine how the government would respond if this was a 25-year-old document-driven fraud
case.
that she remains in de facto solitary confinement, over-managed by multiple guards, and
surveilled by multiple cameras 24 hours per day. The computer equipment provided remains
inadequate to review the millions of pages of discovery under circumstances that are not
conducive to preparing for trial. It is unreasonable to believe that not being able to search, mark,
save, and print is sufficient to prepare this document-laden case for trial. The Court need only
imagine how the government would respond if this was a 25-year-old document-driven fraud
case.
4
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