DOJ-OGR-00020379.jpg
755 KB
Extraction Summary
3
People
4
Organizations
4
Locations
2
Events
2
Relationships
4
Quotes
Document Information
Type:
Legal filing / court document (government response/brief)
File Size:
755 KB
Summary
This document is a page from a government legal filing (Case 21-58) responding to Ghislaine Maxwell's complaints regarding her incarceration conditions at the MDC. The text refutes Maxwell's claims of sewage flooding by clarifying that the cited precedent (Tiffany Days) occurred at the MCC, not the MDC. Additionally, it counters her claim of 'solitary confinement' by detailing her 13-hour daily access to a day room equipped with computers, a phone, and a TV, while noting she requires protective custody for her safety.
People (3)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant/Inmate |
Subject of the legal filing regarding her incarceration conditions at the MDC.
|
| Tiffany Days | Inmate (Case Precedent) |
Referenced by Maxwell's defense to allege sewage flooding; the document distinguishes her experience at MCC from Maxw...
|
| Judge Nathan | District Court Judge |
Judge presiding over the District Court matters (Alison Nathan).
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| MDC |
Metropolitan Detention Center; where Maxwell is currently incarcerated.
|
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| MCC |
Metropolitan Correctional Center; where Tiffany Days experienced sewage flooding.
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| District Court |
S.D.N.Y.; the venue suggested for seeking relief.
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| The Government |
The entity filing this document and ensuring Maxwell's resources.
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Timeline (2 events)
Locations (4)
| Location | Context |
|---|---|
|
Maxwell's place of incarceration.
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|
Location of cited sewage flooding incidents involving Tiffany Days.
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Special Housing Unit; the document notes Maxwell is not housed here.
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Specific area where Maxwell is housed, described as having a day room.
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Relationships (2)
Maxwell uses Days' case to argue poor conditions; Government distinguishes the two based on facility location (MDC vs MCC).
Government suggests complaints about discovery should be raised before Judge Nathan.
Key Quotes (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."Source
DOJ-OGR-00020379.jpg
Quote #1
"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."Source
DOJ-OGR-00020379.jpg
Quote #2
"Although Maxwell complains that she has been 'in solitary confinement'... she does not dispute that it would be unsafe for her to be housed in general population."Source
DOJ-OGR-00020379.jpg
Quote #3
"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."Source
DOJ-OGR-00020379.jpg
Quote #4
Full Extracted Text
Complete text extracted from the document (1,833 characters)
Case 21-58, Document 92, 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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DOJ-OGR-00020379
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