DOJ-OGR-00019831.jpg

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Extraction Summary

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Locations
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Events
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Quotes

Document Information

Type: Legal document
File Size: 627 KB
Summary

This document is a motion for pretrial release for Ghislaine Maxwell, dated April 1, 2021. The motion argues that her constitutional right to prepare for trial is being violated by the harsh conditions of her detention, which allegedly include solitary confinement, sleep deprivation, and exposure to COVID. It further claims her ability to review over 2.5 million pages of discovery and communicate with her lawyers is severely restricted, hindering her trial preparation.

People (1)

Name Role Context
Ghislaine Maxwell Appellant
The subject of the motion, arguing for pretrial release based on the claim that her detention conditions violate her ...

Timeline (2 events)

Ghislaine Maxwell is required to review over 2,500,000 prosecution pages on a 'gutted computer' without search, edit, or print capabilities.
detention facility
Ongoing for over 280 days prior to 2021-04-01
Ghislaine Maxwell's pretrial detention under conditions described as equivalent to solitary confinement, including sleep deprivation, inadequate food, intrusive searches, and being held in a facility with rampant COVID.
squalid facility

Locations (2)

Location Context
The location where Ghislaine Maxwell is being held in pretrial detention, described as a place where COVID has run ra...
The specific cell where Ghislaine Maxwell is held, where lights are shined into it every 15 minutes.

Relationships (1)

Ghislaine Maxwell Professional (Client-Lawyer) Ms. Maxwell's trial lawyers
The document states that 'Ms. Maxwell sees her trial lawyers over a video screen' to review discovery for her case.

Full Extracted Text

Complete text extracted from the document (1,299 characters)

Case 21-58, Document 39-1, 04/01/2021, 3068530, Page3 of 31
Appellant Ghislaine Maxwell’s Motion for Pretrial Release
Ghislaine Maxwell has a Constitutional right to be able to prepare
effectively for trial. The conditions of her pretrial detention deprive her
of that right. For over 280 days, she has been held in the equivalent of
solitary confinement, in deteriorating health and mental condition from
lack of sleep because she is intentionally awakened every 15 minutes by
lights shined directly into her small cell, inadequate food, the constant
glare of neon light, and intrusive searches, including having hands
forced into her mouth in a squalid facility where COVID has run
rampant. The medical literature is unanimous that such conditions
produce mental deterioration, which prevents her from effective
participation in trial preparation.
Worse, even if Ms. Maxwell were able to be fully alert and
mentally acute, she must review over 2,500,000 prosecution pages on a
gutted computer, which does not have the ability to search, edit, or
print. Because of the pandemic, in-person lawyer visits are risky, so
Ms. Maxwell sees her trial lawyers over a video screen, where she can
review one page of the discovery at a time that is projected on a wall
three feet away.
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DOJ-OGR-00019831

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