DOJ-OGR-00020348.jpg
944 KB
Extraction Summary
3
People
5
Organizations
4
Locations
3
Events
2
Relationships
5
Quotes
Document Information
Type:
Legal correspondence/letter to judge
File Size:
944 KB
Summary
A letter from attorney Bobbi C. Sternheim to Judge Alison J. Nathan regarding United States v. Ghislaine Maxwell. The letter raises concerns about Maxwell's conditions of confinement at the MDC, specifically sleep deprivation caused by guards checking her with flashlights every 15 minutes. It also reports a recent incident where Maxwell developed a 'black eye' of unknown origin, leading to threats of punishment (SHU) by MDC staff if she did not explain the injury.
People (3)
| Name | Role | Context |
|---|---|---|
| Bobbi C. Sternheim | Attorney |
Author of the letter, representing Ghislaine Maxwell.
|
| Alison J. Nathan | Judge |
United States District Judge, recipient of the letter.
|
| Ghislaine Maxwell | Defendant/Inmate |
Subject of the letter, currently detained at MDC, reporting issues with sleep deprivation and a black eye.
|
Organizations (5)
| Name | Type | Context |
|---|---|---|
| Law Offices of Bobbi C. Sternheim |
Letterhead organization.
|
|
| United States District Court |
Court where the case is being heard.
|
|
| MDC |
Metropolitan Detention Center where Maxwell is held.
|
|
| The Circuit |
Referenced regarding the bail appeal denial.
|
|
| DOJ |
Department of Justice (referenced in footer ID).
|
Timeline (3 events)
2021-04-28
Ms. Maxwell was confronted by MDC staff due to a visible bruise over her left eye.
MDC
Ghislaine Maxwell
MDC Staff
Unknown
Oral argument of Ghislaine Maxwell's bail appeal before the Circuit.
The Circuit Court
Ghislaine Maxwell's appellate counsel
The Circuit
Unknown (Saturday prior to letter)
Bathroom incident involving guards exerting authority off-camera.
MDC Bathroom
Ghislaine Maxwell
MDC Guards
Locations (4)
| Location | Context |
|---|---|
|
Address of Law Offices of Bobbi C. Sternheim.
|
|
|
Address of United States Courthouse.
|
|
|
Detention facility where Maxwell is held.
|
|
|
Special Housing Unit (threatened placement).
|
Relationships (2)
Sternheim advocating for Maxwell in legal letter.
Judge presiding over Maxwell's case.
Key Quotes (5)
"To the extent Appellant seeks relief specific to her sleeping conditions, such request should be addressed to the District Court."Source
DOJ-OGR-00020348.jpg
Quote #1
"The myth that Ms. Maxwell’s conditions of confinement are related to her being a suicide risk was laid to rest during the oral argument"Source
DOJ-OGR-00020348.jpg
Quote #2
"Last night, she was confronted by MDC staff due a visible bruise over her left eye."Source
DOJ-OGR-00020348.jpg
Quote #3
"threatening to place her in the SHU if she did not reveal how she got it."Source
DOJ-OGR-00020348.jpg
Quote #4
"no guard addressed the bruise until Ms. Maxwell, who has no mirror, caught a reflection of her aching eye in the glean of a nail clipper."Source
DOJ-OGR-00020348.jpg
Quote #5
Full Extracted Text
Complete text extracted from the document (2,896 characters)
Case 1:20-cr-00330-AJN Document 256 Filed 04/29/21 Page 1 of 4
LAW OFFICES OF BOBBI C. STERNHEIM
LAW OFFICES OF BOBBI C. STERNHEIM
212-243-1100 • Main
917-306-6666 • Cell
888-587-4737 • Fax
33 West 19th Street - 4th Floor
New York, New York 10011
bc@sternheimlaw.com
917-306-6666 • Cell
888-587-4737 • Fax
33 West 19th Street - 4th Floor
New York, New York 10011
bc@sternheimlaw.com
April 29, 2021
Honorable Alison J. Nathan
United States District Judge
United States Courthouse
40 Foley Square
New York, NY 10007
United States District Judge
United States Courthouse
40 Foley Square
New York, NY 10007
Re: United States v. Ghislaine Maxwell
S2 20 Cr. 330 (AJN)
S2 20 Cr. 330 (AJN)
Dear Judge Nathan:
During oral argument of Ghislaine Maxwell’s bail appeal before the Circuit, Ms.
Maxwell’s appellate counsel expressed concern that she was improperly deprived of sleep while
detained in the MDC, an issue that has been raised in filings before this Court. In its brief denial
of her appeal, the Circuit stated: “To the extent Appellant seeks relief specific to her sleeping
conditions, such request should be addressed to the District Court.” See Exhibit A. We press our
concerns regarding disruption of Ms. Maxwell’s sleep and the deleterious effect sleep
deprivation is having on her health, well-being, and ability to prepare for and withstand trial.
Maxwell’s appellate counsel expressed concern that she was improperly deprived of sleep while
detained in the MDC, an issue that has been raised in filings before this Court. In its brief denial
of her appeal, the Circuit stated: “To the extent Appellant seeks relief specific to her sleeping
conditions, such request should be addressed to the District Court.” See Exhibit A. We press our
concerns regarding disruption of Ms. Maxwell’s sleep and the deleterious effect sleep
deprivation is having on her health, well-being, and ability to prepare for and withstand trial.
Ms. Maxwell continues to be disrupted throughout the night by guards shining a
flash/strobe light into her cell, claiming that her breathing must be checked. The myth that Ms.
Maxwell’s conditions of confinement are related to her being a suicide risk was laid to rest
during the oral argument: There is nothing to support that contrived claim. In fact, Ms. Maxwell
is classified with the standard CC1-Mh designation: inmate with no significant mental health
care. (See Dkt. 159 at 3.)
flash/strobe light into her cell, claiming that her breathing must be checked. The myth that Ms.
Maxwell’s conditions of confinement are related to her being a suicide risk was laid to rest
during the oral argument: There is nothing to support that contrived claim. In fact, Ms. Maxwell
is classified with the standard CC1-Mh designation: inmate with no significant mental health
care. (See Dkt. 159 at 3.)
Contrary to the report that Ms. Maxwell “wears an eye mask when she sleeps” (Dkt. 196
at 4), an item neither available for purchase through MDC commissary nor provided to her, she
resorts to using a sock or towel to cover her eyes in an awkward attempt to shield them from
disrupting illumination every 15 minutes. Last night, she was confronted by MDC staff due a
visible bruise over her left eye. The “black eye” is depicted in Exhibit B. Despite 24/7 camera
surveillance (except when guards elect to exert authority in an intimidating way off-camera, as
they did in Saturday’s bathroom incident), no guard addressed the bruise until Ms. Maxwell, who
has no mirror, caught a reflection of her aching eye in the glean of a nail clipper. At that point,
MDC staff confronted Ms. Maxwell regarding the source of the bruise, threatening to place her
in the SHU if she did not reveal how she got it. While Ms. Maxwell is unaware of the cause of
the bruise, as reported to medical and psych staff, she has grown increasingly reluctant to report
information to the guards for fear of retaliation, discipline, and punitive chores. However, there
is concern that the bruise may be related to the need for Ms. Maxwell to shield her eyes from the
lights projected into her cell throughout the night.
at 4), an item neither available for purchase through MDC commissary nor provided to her, she
resorts to using a sock or towel to cover her eyes in an awkward attempt to shield them from
disrupting illumination every 15 minutes. Last night, she was confronted by MDC staff due a
visible bruise over her left eye. The “black eye” is depicted in Exhibit B. Despite 24/7 camera
surveillance (except when guards elect to exert authority in an intimidating way off-camera, as
they did in Saturday’s bathroom incident), no guard addressed the bruise until Ms. Maxwell, who
has no mirror, caught a reflection of her aching eye in the glean of a nail clipper. At that point,
MDC staff confronted Ms. Maxwell regarding the source of the bruise, threatening to place her
in the SHU if she did not reveal how she got it. While Ms. Maxwell is unaware of the cause of
the bruise, as reported to medical and psych staff, she has grown increasingly reluctant to report
information to the guards for fear of retaliation, discipline, and punitive chores. However, there
is concern that the bruise may be related to the need for Ms. Maxwell to shield her eyes from the
lights projected into her cell throughout the night.
DOJ-OGR-00020348
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