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754 KB

Extraction Summary

3
People
4
Organizations
3
Locations
2
Events
1
Relationships
1
Quotes

Document Information

Type: Legal document
File Size: 754 KB
Summary

This legal document, part of a court filing, refutes claims made by an inmate named Maxwell regarding her conditions of confinement at the MDC. It distinguishes her situation from a case involving Tiffany Days, who experienced sewage flooding at a different facility (the MCC), and argues there is no evidence of such issues at the MDC. The document also counters Maxwell's claim of being in "solitary confinement" by detailing her daily access to a day room and various amenities for thirteen hours.

People (3)

Name Role Context
Maxwell Inmate/Defendant
Subject of the document, whose complaints about incarceration conditions are being addressed.
Tiffany Days Party in a separate legal case
Her case is cited by Maxwell as an example of sewage flooding, though it occurred at a different facility (MCC).
Judge Nathan Judge
The judge before whom Maxwell is advised to raise her complaints about discovery review.

Organizations (4)

Name Type Context
Metropolitan Correctional Center Correctional facility
Referred to as "MCC", it is the location where Tiffany Days experienced sewage flooding.
MDC Correctional facility
The facility where Maxwell is incarcerated. The document argues there is no evidence of flooding at this location.
District Court Judicial body
The court where Maxwell should seek relief for issues interfering with her trial preparation.
Government Government agency
Mentioned in a footnote as having worked with the MDC to ensure Maxwell has ample resources.

Timeline (2 events)

2021-04-29
Sentencing hearing in the case of United States v. Days, where incidents experienced by Tiffany Days at the MCC were described.
S.D.N.Y.
Maxwell's incarceration at the MDC, during which she has made complaints about her conditions.
MDC

Locations (3)

Location Context
Location of flooding in the Tiffany Days case.
MDC
Location of Maxwell's incarceration.
Southern District of New York, the jurisdiction for the United States v. Days case.

Relationships (1)

Maxwell Legal (Defendant-Judge) Judge Nathan
The document states that Maxwell's complaints about discovery should be raised before Judge Nathan.

Key Quotes (1)

"in solitary confinement"
Source
— Maxwell (A quote from Maxwell's complaint (Mot. at 3) describing her housing situation, which the document argues is inaccurate.)
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Quote #1

Full Extracted Text

Complete text extracted from the document (1,835 characters)

Case 21-770, Document 73, 05/27/2021, 3109708, Page21 of 24
into Maxwell’s unit.4 Maxwell tries to point to the case of Tiffany Days as corroboration of supposed sewage flooding, but she critically omits that the flooding described in the Days case occurred at the Metropolitan Correctional Center (the “MCC”), not the MDC. (See United States v. Days, 19 Cr. 619 (CM) (S.D.N.Y. Apr. 29, 2021), Sentencing Tr. at 13-16 (describing incidents Tiffany Days experienced while at the MCC, including flooding of sewage, before being transferred to the MDC)). There is no evidence in the record from the Days case or this case that there has been any such flooding or sewage backup at the MDC during Maxwell’s incarceration there. To the extent Maxwell suggests that any such issue exists and interferes with her ability to prepare for trial, she can and should seek relief before the District Court. Similarly, Maxwell’s new complaints about her ability to review discovery are best raised in the first instance before Judge Nathan.5
4 Although Maxwell complains that she has been “in solitary confinement” (Mot. at 3), she does not dispute that it would be unsafe for her to be housed in general population. Indeed, Maxwell has never specifically requested a transfer to general population. Nor does she dispute that the MDC has made accommodations so that she is not housed in the SHU while in protective custody. Rather, Maxwell has access to a day room outside of her cell every day for thirteen hours per day, during which she has exclusive access to a desktop computer, a laptop computer, a telephone, a television, and a shower. (See Dkt. 196 at 2).
5 As the Government has noted in the District Court, the Government and MDC have gone to significant lengths to ensure that Maxwell has ample time and resources
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