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684 KB
Extraction Summary
2
People
6
Organizations
1
Locations
2
Events
1
Relationships
6
Quotes
Document Information
Type:
Legal correspondence / court filing
File Size:
684 KB
Summary
This document is page 4 of a legal filing by the Law Offices of Bobbi C. Sternheim on behalf of Ghislaine Maxwell, filed on April 7, 2021. It details complaints regarding Maxwell's confinement conditions at the MDC, including delayed legal mail, unreadable discovery discs, moldy food, sleep deprivation due to lighting and flashlight checks, and 'de facto solitary confinement.' The filing also argues that inadequate computer access hinders her ability to review millions of pages of discovery for her defense.
People (2)
| Name | Role | Context |
|---|---|---|
| Ms. Maxwell | Defendant/Inmate |
Subject of the complaints regarding confinement conditions and legal preparation issues.
|
| Bobbi C. Sternheim | Attorney |
Author of the document/filing (Law Offices of Bobbi C. Sternheim).
|
Organizations (6)
| Name | Type | Context |
|---|---|---|
| Law Offices of Bobbi C. Sternheim |
Defense counsel firm.
|
|
| MDC |
Metropolitan Detention Center - The facility where Maxwell is held.
|
|
| Federal Express |
Courier service used for government mail which was delayed.
|
|
| New York Times |
Newspaper (old issue received by Maxwell).
|
|
| CorrLinks |
Email system used by inmates.
|
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| The Government |
Prosecution/Bureau of Prisons.
|
Timeline (2 events)
2021-03-15
Ms. Maxwell received a copy of the New York Times issued in October (approximate date 'mid-March').
MDC
2021-04-05
Ms. Maxwell was given a salad containing mold (approximate date based on 'earlier this week' relative to April 7 filing).
MDC
Locations (1)
| Location | Context |
|---|---|
|
Metropolitan Detention Center (implied location of confinement).
|
Relationships (1)
Document header: Law Offices of Bobbi C. Sternheim; Content advocates for Maxwell.
Key Quotes (6)
"Even a Federal Express envelope from the government was not given to Ms. Maxwell until two weeks after it was sent"Source
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Quote #1
"MDC violated its own policy by prematurely deleting Ms. Maxwell’s legal emails."Source
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Quote #2
"she was given a salad containing mold earlier this week."Source
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Quote #3
"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."Source
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Quote #4
"she remains in de facto solitary confinement"Source
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Quote #5
"The computer equipment provided remains inadequate to review the millions of pages of discovery"Source
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Quote #6
Full Extracted Text
Complete text extracted from the document (1,954 characters)
Case 1:20-cr-00330-AJN Document 207 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.
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.
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.
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.
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