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674 KB
Extraction Summary
3
People
7
Organizations
2
Locations
3
Events
1
Relationships
6
Quotes
Document Information
Type:
Legal filing / defense attorney letter
File Size:
674 KB
Summary
This document is page 4 of a legal filing by attorney Bobbi C. Sternheim regarding the confinement conditions of Ghislaine Maxwell at the MDC. It details complaints including delayed mail, unreadable discovery discs, moldy food, sleep deprivation due to constant lighting and flashlight checks, and 'de facto solitary confinement.' The filing also argues that inadequate computer equipment is hindering Maxwell's ability to prepare for trial given the massive amount of discovery documents.
People (3)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant/Inmate |
Subject of the complaints regarding confinement conditions and lack of trial preparation resources.
|
| Bobbi C. Sternheim | Attorney |
Author of the legal filing (indicated by letterhead).
|
| Guards | Prison Staff |
Accused of checking cell every 15 minutes with flashlights and over-managing Maxwell.
|
Organizations (7)
| Name | Type | Context |
|---|---|---|
| Law Offices of Bobbi C. Sternheim |
Legal firm representing the defendant.
|
|
| MDC |
Metropolitan Detention Center; the facility where Maxwell is held.
|
|
| Federal Express |
Courier service used for legal mail.
|
|
| New York Times |
Newspaper; an outdated copy was received by Maxwell.
|
|
| CorrLinks |
Email system used by inmates.
|
|
| The Government |
Prosecution; sent discovery materials.
|
|
| DOJ |
Department of Justice (indicated in bates stamp).
|
Timeline (3 events)
Earlier this week (relative to April 7, 2021)
Maxwell provided with a salad containing mold.
MDC
Ms. Maxwell
Locations (2)
| Location | Context |
|---|---|
|
Detention facility where Maxwell is confined.
|
|
|
Specific location of sleep deprivation complaints.
|
Relationships (1)
Document is a filing from Sternheim's law office defending Maxwell.
Key Quotes (6)
"The mail and food issues persist."Source
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Quote #1
"she was given a salad containing mold earlier this week."Source
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Quote #2
"Ms. Maxwell does not have an eye mask; she's not even provided a suitable face mask."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..."Source
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Quote #4
"she remains in de facto solitary confinement, over-managed by multiple guards, and surveilled by multiple cameras 24 hours per day."Source
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Quote #5
"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."Source
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Quote #6
Full Extracted Text
Complete text extracted from the document (1,955 characters)
Case 1:20-cr-00330-AJN Document 197 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.
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.
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.
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.
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.
4
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