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844 KB
Extraction Summary
5
People
4
Organizations
4
Locations
3
Events
2
Relationships
5
Quotes
Document Information
Type:
Legal correspondence / court filing
File Size:
844 KB
Summary
A legal letter from defense attorney Bobbi C. Sternheim to Judge Alison J. Nathan regarding the detention conditions of Ghislaine Maxwell. The letter disputes the government's portrayal of her confinement, alleging mistreatment including the deletion of legal emails, lack of hygiene supplies during quarantine, unauthorized photography of her cell, and lack of medical communication regarding COVID-19 exposure.
People (5)
| Name | Role | Context |
|---|---|---|
| Bobbi C. Sternheim | Defense Counsel |
Author of the letter representing Ghislaine Maxwell.
|
| Alison J. Nathan | United States District Judge |
Recipient of the letter.
|
| Ghislaine Maxwell | Defendant |
Subject of the letter regarding her detention conditions and COVID-19 quarantine.
|
| Unidentified man | Unknown |
Entered Maxwell's isolation cell to take photographs.
|
| Staff member | MDC Staff |
Assigned to Maxwell's isolation pod, tested positive for COVID-19.
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| Law Offices of Bobbi C. Sternheim |
Legal firm representing Maxwell.
|
|
| United States District Court |
Court handling the case.
|
|
| MDC |
Metropolitan Detention Center (implied location of confinement).
|
|
| DOJ |
Department of Justice (indicated in footer).
|
Timeline (3 events)
November 2020
Locations (4)
| Location | Context |
|---|---|
|
Address of Law Offices of Bobbi C. Sternheim.
|
|
|
Address of United States Courthouse.
|
|
|
Facility where Maxwell is detained.
|
|
|
Specific location of Maxwell's confinement.
|
Relationships (2)
As counsel for Ghislaine Maxwell
contact with a staff member... who tested positive for COVID-19
Key Quotes (5)
"Ms. Maxwell was initially quarantined without soap or a toothbrush"Source
DOJ-OGR-00001837.jpg
Quote #1
"all email correspondence between Ms. Maxwell and counsel was deleted in advance of the 180-day period"Source
DOJ-OGR-00001837.jpg
Quote #2
"an unidentified man entered to take photographs and a guard entered to search"Source
DOJ-OGR-00001837.jpg
Quote #3
"Ms. Maxwell was ordered to remove her COVID-protection mask for an in-mouth inspection"Source
DOJ-OGR-00001837.jpg
Quote #4
"medical and psychology staff... have ceased doing so daily since quarantine"Source
DOJ-OGR-00001837.jpg
Quote #5
Full Extracted Text
Complete text extracted from the document (2,534 characters)
Case 1:20-cr-00330-AJN Document 75 Filed 11/24/20 Page 1 of 2
LAW OFFICES OF BOBBI C. STERNHEIM
212-243-1100 • Main
917-306-6666 • Cell
888-587-4737 • Fax
33 West 19th Street - 4th Floor
New York, New York 10011
bc@sternheimlaw.com
LAW OFFICES OF BOBBI C. STERNHEIM
212-243-1100 • Main
917-306-6666 • Cell
888-587-4737 • Fax
33 West 19th Street - 4th Floor
New York, New York 10011
bc@sternheimlaw.com
November 24, 2020
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, I write in response to the government’s letter, dated
November 23, 2020 (see Dkt 74), reporting Ms. Maxwell’s conditions of detention and
confirming that she is currently in quarantine due to contact with a staff member, assigned to her
isolation pod, who tested positive for COVID-19.
November 23, 2020 (see Dkt 74), reporting Ms. Maxwell’s conditions of detention and
confirming that she is currently in quarantine due to contact with a staff member, assigned to her
isolation pod, who tested positive for COVID-19.
The government recites a variety of allowances given Ms. Maxwell, including being
permitted out of her cell three times a week during quarantine for a maximum of 30 minutes, the
total time allotted for showering, making personal calls, and using the CorrLinks email system to
communicate with family and counsel. However, the letter presents an incomplete picture of
Ms. Maxwell’s conditions of confinement.
permitted out of her cell three times a week during quarantine for a maximum of 30 minutes, the
total time allotted for showering, making personal calls, and using the CorrLinks email system to
communicate with family and counsel. However, the letter presents an incomplete picture of
Ms. Maxwell’s conditions of confinement.
The government fails to mention a variety of issues brought to the attention of the MDC,
including but not limited to the fact: that all email correspondence between Ms. Maxwell and
counsel was deleted in advance of the 180-day period, when deletion is expected to occur; that
after being administered two nasal swab tests, under threat of 21-day quarantine if she declined
to be tested, Ms. Maxwell was ordered to remove her COVID-protection mask for an in-mouth
inspection, further risking exposure to the virus; that Ms. Maxwell was initially quarantined
without soap or a toothbrush; that medical and psychology staff, who checked on Ms. Maxwell
daily pre-quarantine, have ceased doing so daily since quarantine and have neither informed her
of results of the COVID tests nor provided information in response to her inquiry regarding what
she should do if she becomes symptomatic.
including but not limited to the fact: that all email correspondence between Ms. Maxwell and
counsel was deleted in advance of the 180-day period, when deletion is expected to occur; that
after being administered two nasal swab tests, under threat of 21-day quarantine if she declined
to be tested, Ms. Maxwell was ordered to remove her COVID-protection mask for an in-mouth
inspection, further risking exposure to the virus; that Ms. Maxwell was initially quarantined
without soap or a toothbrush; that medical and psychology staff, who checked on Ms. Maxwell
daily pre-quarantine, have ceased doing so daily since quarantine and have neither informed her
of results of the COVID tests nor provided information in response to her inquiry regarding what
she should do if she becomes symptomatic.
The letter omits the fact that while staff are not supposed to enter Ms. Maxwell’s
isolation cell during quarantine, an unidentified man entered to take photographs and a guard
entered to search. Further, while counsel assumed that an in-person legal visit scheduled for
Saturday, November 21, would be canceled as a result of Ms. Maxwell’s quarantine status, no
notification was provided; and a request for a substituted legal call was not accommodated.
isolation cell during quarantine, an unidentified man entered to take photographs and a guard
entered to search. Further, while counsel assumed that an in-person legal visit scheduled for
Saturday, November 21, would be canceled as a result of Ms. Maxwell’s quarantine status, no
notification was provided; and a request for a substituted legal call was not accommodated.
DOJ-OGR-00001837
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