DOJ-OGR-00010483.jpg
625 KB
Extraction Summary
1
People
4
Organizations
1
Locations
2
Events
1
Relationships
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Quotes
Document Information
Type:
Legal document
File Size:
625 KB
Summary
This document is a legal filing arguing for a lenient sentence for Ms. Maxwell. It lists numerous mitigating factors for the Court's consideration, including the non-violent nature of offenses from decades ago (1994-2004), her age, lack of prior criminal history, and the extraordinarily harsh conditions of her 22-month pre-sentence detention during the COVID pandemic. The filing also notes that while Probation agrees a downward variance is warranted, it failed to consider the harsh detention conditions in its justification.
People (1)
| Name | Role | Context |
|---|---|---|
| Ms. Maxwell | Defendant |
The subject of the sentencing arguments, mentioned repeatedly throughout the document.
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Organizations (4)
| Name | Type | Context |
|---|---|---|
| Court | Government agency |
The entity being urged to consider several factors when imposing a sentence on Ms. Maxwell.
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| Probation | Government agency |
Mentioned as recognizing that a downward variance is warranted, but criticized for not mentioning detention conditions.
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| CJA Panel | Legal Panel |
A poll was taken of this panel regarding cases where Probation referenced conditions of confinement.
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| Federal Defenders of the Southern and Eastern Districts of New York | Government agency |
A poll was taken of this group regarding cases where Probation referenced conditions of confinement.
|
Timeline (2 events)
1994-2004
The period during which Ms. Maxwell's non-violent offenses occurred, for which she is being sentenced.
Ms. Maxwell served 22 months of pre-sentence detention in solitary confinement during the COVID pandemic.
Locations (1)
| Location | Context |
|---|---|
|
The jurisdiction of the Federal Defenders and CJA Panel that were polled.
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Relationships (1)
The document states, "she has been involved in two committed, long-term, loving relationships with men who had young children."
Full Extracted Text
Complete text extracted from the document (1,761 characters)
Case 1:20-cr-00330-PAE Document 663 Filed 06/15/22 Page 37 of 77
ended. In fact, she has been involved in two committed, long-term, loving relationships with men who had young children. She is not a danger to the community and there is no concern about recidivism.
In imposing an appropriate sentence, we urge the Court to credit a number of factors:
Ms. Maxwell is being sentenced for non-violent offenses which occurred decades ago (1994 to 2004).
Ms. Maxwell is over 60 years old.
Ms. Maxwell is not a danger to the community in any way.
Ms. Maxwell has no prior criminal history or prior bad acts.
Ms. Maxwell has served the entirely of pre-sentence detention during the COVID pandemic.
Ms. Maxwell served 22 months of pre-sentence detention under extraordinarily abnormal and restrictive conditions of solitary confinement as a non-violent defendant who posed no danger to herself or others.
Ms. Maxwell is being sentenced solely for reasons of punishment.
Ms. Maxwell is not being sentenced for rehabilitation.
Ms. Maxwell poses no risk of recidivism.
In addition, Ms. Maxwell’s personal characteristics and history of lawful behavior pre- and and post-dating the offense conduct further distinguishes her situation and warrants sentencing consideration.
Probation recognizes that a downward variance is warranted in this case. However, noticeably absent from Probation’s justification is any mention of detention served during the pandemic and under harsh conditions of solitary confinement. A poll taken of the CJA Panel and Federal Defenders of the Southern and Eastern Districts of New York has resulted in no cases where Probation has referenced conditions of confinement or COVID, despite requests by defense
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DOJ-OGR-00010483
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