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981 KB
Extraction Summary
4
People
5
Organizations
3
Locations
2
Events
2
Relationships
3
Quotes
Document Information
Type:
Legal filing / court order
File Size:
981 KB
Summary
This document is a legal letter from defense attorney Bobbi C. Sternheim to Judge Alison J. Nathan, filed on November 24, 2020, regarding the pretrial detention conditions of Ghislaine Maxwell at the MDC. The defense alleges excessive surveillance, sleep deprivation via flashlight checks every 15 minutes, and isolation, requesting that Warden Heriberto Tellez be summoned to address the court. The document includes a hand-signed order by Judge Nathan requiring the parties to meet and confer regarding the request for the Warden to address these concerns.
People (4)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant / Pretrial Detainee |
Subject of the letter; described as enduring harsh detention conditions including sleep deprivation and excessive sur...
|
| Bobbi C. Sternheim | Defense Counsel |
Author of the letter advocating for better conditions for Maxwell.
|
| Heriberto Tellez | Warden |
Warden of the detention center; the defense requests he be summoned to report to the Court.
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| Alison J. Nathan | U.S. District Judge |
Judge presiding over the case who signed the order at the bottom of the document.
|
Organizations (5)
| Name | Type | Context |
|---|---|---|
| Law Offices of Bobbi C. Sternheim |
Letterhead source.
|
|
| MDC |
Metropolitan Detention Center (Brooklyn); where Maxwell is being held.
|
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| BOP |
Bureau of Prisons; operates the facilities mentioned.
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|
| MCC |
Metropolitan Correctional Center; mentioned for comparison regarding its restrictive 10South unit.
|
|
| FCI Florence ADMAX |
Supermax prison mentioned for comparison regarding restrictive conditions.
|
Timeline (2 events)
2020-11-24
Filing of defense letter regarding detention conditions.
Court Docket (SDNY)
2020-11-24
Judge signs order requiring parties to meet and confer regarding Warden Tellez.
Court Docket (SDNY)
Locations (3)
| Location | Context |
|---|---|
|
Current location of Ghislaine Maxwell.
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|
|
Restrictive unit in MCC used for comparison.
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|
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High-security facility used for comparison.
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Relationships (2)
Sternheim writes on behalf of Maxwell as her counsel.
Tellez is the Warden of the facility where Maxwell is detained.
Key Quotes (3)
"Ms. Maxwell's sleep is disrupted every 15-minutes when she is awakened by a flashlight to ascertain whether she is breathing."Source
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Quote #1
"She is overmanaged under conditions more restrictive than inmates housed in 10South... or individuals convicted of terrorism and capital murder and incarcerated at FCI Florence ADMAX..."Source
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Quote #2
"The parties are hereby ORDERED to meet and confer regarding Defendant's request that Warden Heriberto Tellez directly address Defendant's concerns regarding the conditions of her detention."Source
DOJ-OGR-00001840.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (2,967 characters)
Case 1:20-cr-00330-AJN Document 76 Filed 11/24/20 Page 2 of 2
LAW OFFICES OF BOBBI C. STERNHEIM
LAW OFFICES OF BOBBI C. STERNHEIM
The government highlights what Ms. Maxwell is permitted but not what she is denied:
equal treatment accorded other inmates in general population. Ms. Maxwell has spent the
entirely of her pretrial detention in de facto solitary confinement under the most restrictive
conditions where she is excessively and invasively searched and is monitored 24 hours per day.
In addition to camera surveillance in her cell, a supplemental camera follows her movement
when she is permitted to leave her isolation cell and is focused on Ms. Maxwell and counsel
during in-person legal visits. And despite non-stop in-cell camera surveillance, Ms. Maxwell’s
sleep is disrupted every 15-minutes when she is awakened by a flashlight to ascertain whether
she is breathing.
equal treatment accorded other inmates in general population. Ms. Maxwell has spent the
entirely of her pretrial detention in de facto solitary confinement under the most restrictive
conditions where she is excessively and invasively searched and is monitored 24 hours per day.
In addition to camera surveillance in her cell, a supplemental camera follows her movement
when she is permitted to leave her isolation cell and is focused on Ms. Maxwell and counsel
during in-person legal visits. And despite non-stop in-cell camera surveillance, Ms. Maxwell’s
sleep is disrupted every 15-minutes when she is awakened by a flashlight to ascertain whether
she is breathing.
Ms. Maxwell is a non-violent, exemplary pretrial detainee with no criminal history, no
history of violence, no history of mental health issues or suicidal ideation. She is overmanaged
under conditions more restrictive than inmates housed in 10South, the most restrictive unit in the
MCC; or individuals convicted of terrorism and capital murder and incarcerated at FCI Florence
ADMAX, the most restrictive facility operated by the BOP. The MDC concedes that it is unable
to place her in general population for her safety and the security of the institution but fails to
explain why she is deprived of all other opportunities provided to general population inmates.
history of violence, no history of mental health issues or suicidal ideation. She is overmanaged
under conditions more restrictive than inmates housed in 10South, the most restrictive unit in the
MCC; or individuals convicted of terrorism and capital murder and incarcerated at FCI Florence
ADMAX, the most restrictive facility operated by the BOP. The MDC concedes that it is unable
to place her in general population for her safety and the security of the institution but fails to
explain why she is deprived of all other opportunities provided to general population inmates.
Stating that Ms. Maxwell “continues to have more time to review her discovery than any
other inmate at the MDC, even while in quarantine” gives the unfair impression that she is being
given a perquisite. However, given the voluminous discovery in this case, the most recent
production alone being 1.2 million documents, the time accorded Ms. Maxwell remains
inadequate for her to review and prepare the defense of her life.
other inmate at the MDC, even while in quarantine” gives the unfair impression that she is being
given a perquisite. However, given the voluminous discovery in this case, the most recent
production alone being 1.2 million documents, the time accorded Ms. Maxwell remains
inadequate for her to review and prepare the defense of her life.
Due to the failure of MDC’s Warden and Legal Department to respond to recurring
problems and complaints, counsel have reached out to the government. While we appreciate any
assistance provided by government counsel, it has done little to redress the many concerns
regarding the disparate treatment of Ms. Maxwell.
problems and complaints, counsel have reached out to the government. While we appreciate any
assistance provided by government counsel, it has done little to redress the many concerns
regarding the disparate treatment of Ms. Maxwell.
Rather than receive second-hand information from counsel, the defense requests that the
Court summon Warden Heriberto Tellez to report directly to the Court and counsel on Ms.
Maxwell’s conditions of detention.
Court summon Warden Heriberto Tellez to report directly to the Court and counsel on Ms.
Maxwell’s conditions of detention.
Your consideration is greatly appreciated.
Very truly yours,
Bobbi C. Sternheim
BOBBI C. STERNHEIM
Bobbi C. Sternheim
BOBBI C. STERNHEIM
cc: All Counsel
SO ORDERED. 11/24/20
Alison J. Nathan
Alison J. Nathan, U.S.D.J.
2
Alison J. Nathan
Alison J. Nathan, U.S.D.J.
2
[Boxed Text]:
The parties are hereby ORDERED to meet
and confer regarding Defendant's request
that Warden Heriberto Tellez directly
address Defendant's concerns regarding
the conditions of her detention. The
parties shall jointly submit a status update
within one week of this Order.
SO ORDERED.
The parties are hereby ORDERED to meet
and confer regarding Defendant's request
that Warden Heriberto Tellez directly
address Defendant's concerns regarding
the conditions of her detention. The
parties shall jointly submit a status update
within one week of this Order.
SO ORDERED.
DOJ-OGR-00001840
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