DOJ-OGR-00002014.jpg
762 KB
Extraction Summary
3
People
5
Organizations
1
Locations
4
Events
2
Relationships
1
Quotes
Document Information
Type:
Legal document
File Size:
762 KB
Summary
This legal document, filed on behalf of Ms. Maxwell, argues that her pretrial detention conditions at the MDC are excessively punitive and inappropriate. Her counsel asserts these conditions—including de facto solitary confinement and constant surveillance—are an overreaction to Epstein's death, are disproportionate for a non-violent detainee, and are impeding her ability to prepare a defense. The document references multiple unsuccessful attempts by counsel to remedy the situation through communication with the MDC, its legal department, and prosecutors.
People (3)
| Name | Role | Context |
|---|---|---|
| Epstein |
Mentioned in the context of his death, which allegedly led to an exaggerated response in Ms. Maxwell's treatment.
|
|
| Ms. Maxwell | pretrial detainee |
The subject of the document, whose conditions of detention are being challenged by her counsel.
|
| MDC warden | Warden |
Recipient of letters, emails, and calls from Ms. Maxwell's counsel regarding her detention conditions. Mentioned as n...
|
Organizations (5)
| Name | Type | Context |
|---|---|---|
| BOP | government agency |
Bureau of Prisons, accused of negligence regarding Epstein's death and of punishing Ms. Maxwell for it.
|
| MDC | government facility |
Metropolitan Detention Center, where Ms. Maxwell is being held.
|
| MDC legal department | government agency |
Recipient of communications from Ms. Maxwell's counsel. Submitted a letter to the Court regarding MDC conditions.
|
| The Court | government agency |
The judicial body being addressed in the legal filing.
|
| DOJ-OGR | government agency |
Appears in the footer of the document (DOJ-OGR-00002014).
|
Timeline (4 events)
2020-10-29
Counsel sent a letter to the MDC warden detailing the restrictive conditions of Ms. Maxwell's confinement.
Counsel
MDC warden
Ms. Maxwell's pretrial detention under conditions described as solitary confinement, excessive surveillance, and deprivation.
MDC
Locations (1)
| Location | Context |
|---|---|
|
The location where Ms. Maxwell is detained under the conditions described in the document.
|
Relationships (2)
Counsel is representing Ms. Maxwell and arguing on her behalf to the Court regarding her detention conditions.
Counsel has sent numerous communications to the warden to address Ms. Maxwell's conditions, but states the warden has not responded to a specific letter.
Key Quotes (1)
"It is the height of irony that Ms. Maxwell is being constantly surveilled as if she were a suicide risk when she, herself, is trusted enough (if she were ever released from isolation) to monitor inmates who are truly at risk of suicide."Source
— Counsel for Ms. Maxwell
(From a footnote arguing that the conditions are inappropriate because Ms. Maxwell is an exemplary inmate who has been given the responsibility of a suicide watch inmate.)
DOJ-OGR-00002014.jpg
Quote #1
Full Extracted Text
Complete text extracted from the document (2,473 characters)
Case 1:20-cr-00330-AJN Document 97 Filed 12/14/20 Page 42 of 45
exaggerated response to Epstein’s death, effectively punishing Ms. Maxwell for the BOP’s own
negligence with respect to Epstein.11
negligence with respect to Epstein.11
Counsel has attempted to address the restrictions in numerous letters, emails and calls to
the MDC warden, the MDC legal department, and the prosecutors, but to no avail. Rather than
repeating these points here at length, we refer the Court to our letter to the MDC warden, dated
October 29, 2020, which details the most serious and extraordinarily restrictive conditions of
confinement.12 These include:
the MDC warden, the MDC legal department, and the prosecutors, but to no avail. Rather than
repeating these points here at length, we refer the Court to our letter to the MDC warden, dated
October 29, 2020, which details the most serious and extraordinarily restrictive conditions of
confinement.12 These include:
■ De Facto Solitary Confinement
■ Excessive Surveillance
■ Excessive Scanning and Strip Searching
■ Deprivation of Food
■ Deprivation of Sleep
■ Deprivation of Communication with Family and Friends
■ Compromised Communication with Legal Counsel
■ Excessive Surveillance
■ Excessive Scanning and Strip Searching
■ Deprivation of Food
■ Deprivation of Sleep
■ Deprivation of Communication with Family and Friends
■ Compromised Communication with Legal Counsel
The conditions of Ms. Maxwell’s detention are utterly inappropriate, and totally disproportionate
for a non-violent pretrial detainee with no prior criminal history facing non-violent charges a
quarter-century old. Moreover, they adversely impact her ability to prepare her defense and
compromise her physical health and psychological wellbeing.
for a non-violent pretrial detainee with no prior criminal history facing non-violent charges a
quarter-century old. Moreover, they adversely impact her ability to prepare her defense and
compromise her physical health and psychological wellbeing.
In addition to these intolerable conditions, Ms. Maxwell has had to contend with
numerous unacceptable delays and technical problems with the discovery that the government
has produced to her thus far. We have raised these issues with the prosecutors on numerous
occasions. As we advised the Court in our letter of October 23, 2020, defense counsel first
numerous unacceptable delays and technical problems with the discovery that the government
has produced to her thus far. We have raised these issues with the prosecutors on numerous
occasions. As we advised the Court in our letter of October 23, 2020, defense counsel first
11 These conditions are especially inappropriate because Ms. Maxwell has been an exemplary inmate and has not
received any disciplinary infractions since her arrest. In fact, she has been made a suicide watch inmate, which is
the highest and most trusted responsibility that an inmate can have. It is the height of irony that Ms. Maxwell is
being constantly surveilled as if she were a suicide risk when she, herself, is trusted enough (if she were ever
released from isolation) to monitor inmates who are truly at risk of suicide.
received any disciplinary infractions since her arrest. In fact, she has been made a suicide watch inmate, which is
the highest and most trusted responsibility that an inmate can have. It is the height of irony that Ms. Maxwell is
being constantly surveilled as if she were a suicide risk when she, herself, is trusted enough (if she were ever
released from isolation) to monitor inmates who are truly at risk of suicide.
12 The Warden never responded to the letter. In our response to the government’s 90-day status report concerning
MDC conditions, counsel requested that the Warden provide a first-hand report to the Court and counsel. Following
Court directive for a report from the MDC, MDC Legal submitted a letter that recited BOP policy but failed to
address a number of concerns.
MDC conditions, counsel requested that the Warden provide a first-hand report to the Court and counsel. Following
Court directive for a report from the MDC, MDC Legal submitted a letter that recited BOP policy but failed to
address a number of concerns.
36
DOJ-OGR-00002014
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