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929 KB
Extraction Summary
5
People
5
Organizations
2
Locations
4
Events
2
Relationships
5
Quotes
Document Information
Type:
Legal filing / defense letter (page 2 of 3)
File Size:
929 KB
Summary
This document is page 2 of a legal filing by attorney Bobbi C. Sternheim regarding the confinement conditions of Ghislaine Maxwell at the MDC. The text alleges severe mistreatment by prison staff, including physical abuse, withholding of food, destruction of legal documents, and excessive surveillance (including filming her showers). It also argues against flight risk allegations by citing monitored calls that demonstrate Maxwell's strong ties to the United States and desire to clear her name.
People (5)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant / Inmate |
Subject of the letter, describing her conditions of confinement and alleged mistreatment at MDC.
|
| Bobbi C. Sternheim | Defense Attorney |
Author of the document (letterhead).
|
| MDC Staff / Guards | Prison Staff |
Accused of leaking info, physical abuse, withholding food, and excessive surveillance.
|
| Psychological Services Staff | Prison Medical Staff |
Accused of confronting Maxwell about a personal death using information gleaned from monitored calls.
|
| Unnamed Deceased Person | Associate of Maxwell |
Someone 'quite dear' to Maxwell who passed away; used as an example of surveillance intrusion.
|
Organizations (5)
| Name | Type | Context |
|---|---|---|
| Law Offices of Bobbi C. Sternheim |
Legal firm representing Maxwell.
|
|
| MDC |
Metropolitan Detention Center (Brooklyn), where Maxwell is detained.
|
|
| BOP |
Bureau of Prisons, referenced regarding procedures (BP-8s, etc.).
|
|
| The Court |
Southern District of New York (implied by case number AJN).
|
|
| The Press |
Recipients of leaked information regarding Maxwell's vaccination.
|
Timeline (4 events)
Prior to May 2021
Prior to May 2021
MDC staff leaked to the press that Maxwell was vaccinated.
MDC
Specific date unknown
Specific date unknown
Staff confronted Maxwell about the death of a close friend hours after she learned of it.
MDC
Ghislaine Maxwell
MDC Staff/Psych Services
Locations (2)
| Location | Context |
|---|---|
|
Metropolitan Detention Center, likely Brooklyn, NY.
|
|
|
Location of Maxwell's family ties and trial.
|
Relationships (2)
Document is a legal filing by Sternheim on behalf of Maxwell.
Allegations of abuse, surveillance, and harassment detailed in the text.
Key Quotes (5)
"Ironically, it is the MDC staff who leaked to the press that Ms. Maxwell had been vaccinated."Source
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Quote #1
"Her de facto solitary confinement prevents her from utilizing that training to assist others."Source
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Quote #2
"It is not only other inmates who may harm Ms. Maxwell, but also the very guards tasked to her security detail who have already done harm to her: failing to provide adequate food or feed her at all in a 20-hour period, damaging her discovery hard drive, seizing her confidential legal documents, erasing her CorrLinks emails, physically abusing her."Source
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Quote #3
"Each and every day of her detention, she is guarded by at least three officers who watch and record, by writing and via a handheld camera, her every move: when she eats, showers, cleans her clothes, brushes her teeth, etc."Source
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Quote #4
"It was psychological services who confronted her regarding that information, which could only have been obtained through telephone surveillance."Source
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Quote #5
Full Extracted Text
Complete text extracted from the document (2,831 characters)
Case 1:20-cr-00330-AJN Document 272 Filed 05/07/21 Page 2 of 3
LAW OFFICES OF BOBBI C. STERNHEIM
LAW OFFICES OF BOBBI C. STERNHEIM
Form listed “psych alerts,” which are baseless, and “broad publicity,” which is accurate and
concerns risk of harm to Ms. Maxwell via violence, extortion, and feed information to the press
by other inmates. Ironically, it is the MDC staff who leaked to the press that Ms. Maxwell had
been vaccinated.
concerns risk of harm to Ms. Maxwell via violence, extortion, and feed information to the press
by other inmates. Ironically, it is the MDC staff who leaked to the press that Ms. Maxwell had
been vaccinated.
Further, in her desire to interact and be helpful with other inmates, Ms. Maxwell
completed two programs to assist other inmates- (1) to qualify as a teacher aide and offered to
help update MDC learning curriculum and (2) to qualify as companion for suicide watch. Her
de facto solitary confinement prevents her from utilizing that training to assist others.
completed two programs to assist other inmates- (1) to qualify as a teacher aide and offered to
help update MDC learning curriculum and (2) to qualify as companion for suicide watch. Her
de facto solitary confinement prevents her from utilizing that training to assist others.
Ms. Maxwell’s segregation and surveillance go way beyond the concerns posited by the
MDC. It is not only other inmates who may harm Ms. Maxwell, but also the very guards tasked
to her security detail who have already done harm to her: failing to provide adequate food or feed
her at all in a 20-hour period, damaging her discovery hard drive, seizing her confidential legal
documents, erasing her CorrLinks emails, physically abusing her. The list goes on and on. In an
effort to advocate in compliance with BOP procedure, she has filed hundreds of BP-8s, BP-9s
and BP-10s only to receive a response that is less than helpful, or in the absence of any response
was told the form was either lost or never filed, Each and every day of her detention, she is
guarded by at least three officers who watch and record, by writing and via a handheld camera,
her every move: when she eats, showers, cleans her clothes, brushes her teeth, etc. As the guards
feverishly write while observing Ms. Maxwell during videoconferencing with counsel, it appears
that they go beyond their routine continual 15-minute reporting.
MDC. It is not only other inmates who may harm Ms. Maxwell, but also the very guards tasked
to her security detail who have already done harm to her: failing to provide adequate food or feed
her at all in a 20-hour period, damaging her discovery hard drive, seizing her confidential legal
documents, erasing her CorrLinks emails, physically abusing her. The list goes on and on. In an
effort to advocate in compliance with BOP procedure, she has filed hundreds of BP-8s, BP-9s
and BP-10s only to receive a response that is less than helpful, or in the absence of any response
was told the form was either lost or never filed, Each and every day of her detention, she is
guarded by at least three officers who watch and record, by writing and via a handheld camera,
her every move: when she eats, showers, cleans her clothes, brushes her teeth, etc. As the guards
feverishly write while observing Ms. Maxwell during videoconferencing with counsel, it appears
that they go beyond their routine continual 15-minute reporting.
Further, her non-legal phone calls are monitored in real time. It was the staff who
confronted Ms. Maxwell about the death of someone whom she was close to within hours on her
learning about it, information derived from her phone calls. Ms. Maxwell does not discuss
personal matters with MDC guards and did not provide information concerning the passing of
someone quite dear to her. It was psychological services who confronted her regarding that
information, which could only have been obtained through telephone surveillance. We invite the
Court and government to review the calls which contradict the unsupported allegation that Ms.
Maxwell is a flight risk and support her family strong ties. Her monitored communication with
family and friends evidences her strong ties in the United States, her strong desire to return to her
family in the United States, and her intention to establish her innocence at her trial in the United
States.
confronted Ms. Maxwell about the death of someone whom she was close to within hours on her
learning about it, information derived from her phone calls. Ms. Maxwell does not discuss
personal matters with MDC guards and did not provide information concerning the passing of
someone quite dear to her. It was psychological services who confronted her regarding that
information, which could only have been obtained through telephone surveillance. We invite the
Court and government to review the calls which contradict the unsupported allegation that Ms.
Maxwell is a flight risk and support her family strong ties. Her monitored communication with
family and friends evidences her strong ties in the United States, her strong desire to return to her
family in the United States, and her intention to establish her innocence at her trial in the United
States.
2
DOJ-OGR-00001439
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