DOJ-OGR-00020094.jpg
818 KB
Extraction Summary
5
People
3
Organizations
1
Locations
2
Events
1
Relationships
4
Quotes
Document Information
Type:
Court filing / government response (legal brief)
File Size:
818 KB
Summary
This document is a page from a Government court filing (Case 1:20-cr-00330-AJN, likely USA v. Maxwell) dated December 18, 2020. It addresses defense complaints regarding discovery access, noting that one hard drive malfunctioned because the defendant dropped it, and details her special confinement conditions at the MDC, which include 13 hours out of cell, private shower, computers, phone, and TV. A footnote highlights a contradiction in the defense's arguments regarding the value of discovery versus the prejudice caused by delays.
People (5)
| Name | Role | Context |
|---|---|---|
| The Defendant | Defendant / Inmate |
Subject of the confinement conditions and discovery disputes (Implied to be Ghislaine Maxwell based on Case 1:20-cr-0...
|
| The Defense | Legal Counsel |
Representing the defendant, raising complaints about discovery and confinement.
|
| The Government | Prosecution |
Responding to defense complaints, managing discovery production.
|
| IT staff | Technical Support |
Offered by Government to review malfunctioning drives.
|
| MDC legal counsel | Prison Legal Staff |
Coordinating with the Government regarding defendant's access to counsel.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| MDC |
Metropolitan Detention Center (place of confinement)
|
|
| The Government |
Department of Justice / Prosecution
|
|
| DOJ-OGR |
Department of Justice - Office of Government Relations (implied by footer stamp)
|
Timeline (2 events)
Prior to 2020-12-18
Defendant dropped a hard drive containing the sixth discovery production onto the ground.
MDC
Locations (1)
| Location | Context |
|---|---|
|
Metropolitan Detention Center (Detention facility where defendant is held)
|
Relationships (1)
The Government will continue to work with MDC legal counsel to ensure that the defendant is able to review her discovery
Key Quotes (4)
"the malfunctioning of the sixth production that the defense complains of resulted from the defendant herself dropping the hard drive onto the ground"Source
DOJ-OGR-00020094.jpg
Quote #1
"the defendant is released from her isolation cell for thirteen hours per day, has her own shower, has exclusive use of two different computers, has her own phone to use, and has her own television."Source
DOJ-OGR-00020094.jpg
Quote #2
"Those conditions set her far apart from general population inmates"Source
DOJ-OGR-00020094.jpg
Quote #3
"the Government notes the tension between the defense claim that the discovery produced to date contains little of value... and the simultaneous claim that the defendant has been prejudiced by technical difficulties"Source
DOJ-OGR-00020094.jpg
Quote #4
Full Extracted Text
Complete text extracted from the document (2,438 characters)
Case 1:20-cr-00330-AJN Document 102 Filed 12/18/20 Page 36 of 36
As to the defense’s most recent complaints, the malfunctioning of the sixth production that
the defense complains of resulted from the defendant herself dropping the hard drive onto the
ground, and that drive has been replaced. When the defense informed the Government that the
drive containing the seventh production may be malfunctioning, the Government offered to have
IT staff review the drive. In response, the defense indicated the drive was in fact still viewable
and declined to have IT staff review it. Accordingly, it is the Government’s understanding that
the defendant currently has a full, readable set of discovery at the MDC. At the defense’s request,
the Government is preparing yet another copy containing all productions to date on a single drive
so that the defendant will have a backup copy of discovery materials at the MDC.11 Throughout
the defendant’s pretrial detention, the Government has been responsive to the defense’s concerns
regarding access to discovery and counsel. The Government will continue to work with MDC
legal counsel to ensure that the defendant is able to review her discovery and communicate with
defense counsel over the seven months still remaining before trial.
the defense complains of resulted from the defendant herself dropping the hard drive onto the
ground, and that drive has been replaced. When the defense informed the Government that the
drive containing the seventh production may be malfunctioning, the Government offered to have
IT staff review the drive. In response, the defense indicated the drive was in fact still viewable
and declined to have IT staff review it. Accordingly, it is the Government’s understanding that
the defendant currently has a full, readable set of discovery at the MDC. At the defense’s request,
the Government is preparing yet another copy containing all productions to date on a single drive
so that the defendant will have a backup copy of discovery materials at the MDC.11 Throughout
the defendant’s pretrial detention, the Government has been responsive to the defense’s concerns
regarding access to discovery and counsel. The Government will continue to work with MDC
legal counsel to ensure that the defendant is able to review her discovery and communicate with
defense counsel over the seven months still remaining before trial.
As to the defense complaints regarding the defendant’s conditions of confinement, the
defense notably does not suggest that the defendant should be housed in general population.
Indeed, the defense appears to agree that the best way to ensure the defendant’s safety while
detained is to be away from general population. Unlike other inmates in protective custody,
however, the defendant is released from her isolation cell for thirteen hours per day, has her own
shower, has exclusive use of two different computers, has her own phone to use, and has her own
television. Those conditions set her far apart from general population inmates, not to mention
defense notably does not suggest that the defendant should be housed in general population.
Indeed, the defense appears to agree that the best way to ensure the defendant’s safety while
detained is to be away from general population. Unlike other inmates in protective custody,
however, the defendant is released from her isolation cell for thirteen hours per day, has her own
shower, has exclusive use of two different computers, has her own phone to use, and has her own
television. Those conditions set her far apart from general population inmates, not to mention
11 On this score, the Government notes the tension between the defense claim that the discovery
produced to date contains little of value or relevant to the charges set forth in the Indictment, and
the simultaneous claim that the defendant has been prejudiced by technical difficulties that have
temporarily delayed her ability to review portions of those productions, productions which,
according to the defense, counsel have already been able to conclude are essentially unimportant.
produced to date contains little of value or relevant to the charges set forth in the Indictment, and
the simultaneous claim that the defendant has been prejudiced by technical difficulties that have
temporarily delayed her ability to review portions of those productions, productions which,
according to the defense, counsel have already been able to conclude are essentially unimportant.
31
DOJ-OGR-00020094
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