DOJ-OGR-00001839.jpg
874 KB
Extraction Summary
6
People
4
Organizations
4
Locations
4
Events
2
Relationships
5
Quotes
Document Information
Type:
Legal correspondence / court filing
File Size:
874 KB
Summary
A letter from defense attorney Bobbi C. Sternheim to Judge Alison J. Nathan dated November 24, 2020, regarding United States v. Ghislaine Maxwell. The letter details harsh detention conditions at the MDC, including Maxwell being quarantined due to COVID-19 exposure from a staff member, deletion of attorney-client emails, lack of hygiene supplies (soap/toothbrush), unauthorized photography of her cell, and the cancellation of legal visits without notice.
People (6)
| Name | Role | Context |
|---|---|---|
| Bobbi C. Sternheim | Defense Attorney |
Author of the letter, counsel for Ghislaine Maxwell.
|
| Alison J. Nathan | United States District Judge |
Recipient of the letter, presiding over US v. Ghislaine Maxwell.
|
| Ghislaine Maxwell | Defendant |
Subject of the letter, currently in detention and quarantine at MDC.
|
| Unidentified Staff Member | Prison Staff |
Assigned to Maxwell's isolation pod, tested positive for COVID-19.
|
| Unidentified Man | Unknown |
Entered Maxwell's isolation cell to take photographs during quarantine.
|
| Unidentified Guard | Prison Guard |
Entered Maxwell's isolation cell to search it during quarantine.
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| Law Offices of Bobbi C. Sternheim |
Defense counsel's firm.
|
|
| United States District Court (SDNY) |
Court where the document was filed.
|
|
| MDC |
Metropolitan Detention Center, where Maxwell is confined.
|
|
| DOJ |
Department of Justice (referenced in footer DOJ-OGR).
|
Timeline (4 events)
November 2020
Ghislaine Maxwell placed in quarantine after contact with COVID-positive staff member.
MDC Isolation Pod
Ghislaine Maxwell
Staff Member
November 21, 2020
Scheduled in-person legal visit was effectively canceled due to quarantine without notification.
MDC
Ghislaine Maxwell
Counsel
Unknown (Recent)
Unidentified man entered Maxwell's isolation cell to take photographs.
MDC Isolation Cell
Unknown (Recent)
Locations (4)
| Location | Context |
|---|---|
|
Address of Law Offices of Bobbi C. Sternheim.
|
|
|
Address of United States Courthouse.
|
|
|
Detention facility.
|
|
|
Specific location of Maxwell's confinement.
|
Relationships (2)
As counsel for Ghislaine Maxwell
contact with a staff member, assigned to her isolation pod, who tested positive for COVID-19
Key Quotes (5)
"Ms. Maxwell was initially quarantined without soap or a toothbrush"Source
DOJ-OGR-00001839.jpg
Quote #1
"an unidentified man entered to take photographs and a guard entered to search"Source
DOJ-OGR-00001839.jpg
Quote #2
"all email correspondence between Ms. Maxwell and counsel was deleted in advance of the 180-day period"Source
DOJ-OGR-00001839.jpg
Quote #3
"Ms. Maxwell was ordered to remove her COVID-protection mask for an in-mouth inspection, further risking exposure to the virus"Source
DOJ-OGR-00001839.jpg
Quote #4
"medical and psychology staff... have ceased doing so daily since quarantine"Source
DOJ-OGR-00001839.jpg
Quote #5
Full Extracted Text
Complete text extracted from the document (2,606 characters)
Case 1:20-cr-00330-AJN Document 76 Filed 11/24/20 Page 1 of 2
LAW OFFICES OF BOBBI C. STERNHEIM
212-243-1100 • Main
917-306-6666 • Cell
888-587-4737 • Fax
917-306-6666 • Cell
888-587-4737 • Fax
33 West 19th Street - 4th Floor
New York, New York 10011
bc@sternheimlaw.com
New York, New York 10011
bc@sternheimlaw.com
USDC SDNY
DOCUMENT
ELECTRONICALLY FILED
DOC #:
DATE FILED: 11/24/20
DOCUMENT
ELECTRONICALLY FILED
DOC #:
DATE FILED: 11/24/20
November 24, 2020
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
20 Cr. 330 (AJN)
20 Cr. 330 (AJN)
Dear Judge Nathan:
As counsel for Ghislaine Maxwell, I write in response to the government’s letter, dated
November 23, 2020 (see Dkt 74), reporting Ms. Maxwell’s conditions of detention and
confirming that she is currently in quarantine due to contact with a staff member, assigned to her
isolation pod, who tested positive for COVID-19.
November 23, 2020 (see Dkt 74), reporting Ms. Maxwell’s conditions of detention and
confirming that she is currently in quarantine due to contact with a staff member, assigned to her
isolation pod, who tested positive for COVID-19.
The government recites a variety of allowances given Ms. Maxwell, including being
permitted out of her cell three times a week during quarantine for a maximum of 30 minutes, the
total time allotted for showering, making personal calls, and using the CorrLinks email system to
communicate with family and counsel. However, the letter presents an incomplete picture of
Ms. Maxwell’s conditions of confinement.
permitted out of her cell three times a week during quarantine for a maximum of 30 minutes, the
total time allotted for showering, making personal calls, and using the CorrLinks email system to
communicate with family and counsel. However, the letter presents an incomplete picture of
Ms. Maxwell’s conditions of confinement.
The government fails to mention a variety of issues brought to the attention of the MDC,
including but not limited to the fact: that all email correspondence between Ms. Maxwell and
counsel was deleted in advance of the 180-day period, when deletion is expected to occur; that
after being administered two nasal swab tests, under threat of 21-day quarantine if she declined
to be tested, Ms. Maxwell was ordered to remove her COVID-protection mask for an in-mouth
inspection, further risking exposure to the virus; that Ms. Maxwell was initially quarantined
without soap or a toothbrush; that medical and psychology staff, who checked on Ms. Maxwell
daily pre-quarantine, have ceased doing so daily since quarantine and have neither informed her
of results of the COVID tests nor provided information in response to her inquiry regarding what
she should do if she becomes symptomatic.
including but not limited to the fact: that all email correspondence between Ms. Maxwell and
counsel was deleted in advance of the 180-day period, when deletion is expected to occur; that
after being administered two nasal swab tests, under threat of 21-day quarantine if she declined
to be tested, Ms. Maxwell was ordered to remove her COVID-protection mask for an in-mouth
inspection, further risking exposure to the virus; that Ms. Maxwell was initially quarantined
without soap or a toothbrush; that medical and psychology staff, who checked on Ms. Maxwell
daily pre-quarantine, have ceased doing so daily since quarantine and have neither informed her
of results of the COVID tests nor provided information in response to her inquiry regarding what
she should do if she becomes symptomatic.
The letter omits the fact that while staff are not supposed to enter Ms. Maxwell’s
isolation cell during quarantine, an unidentified man entered to take photographs and a guard
entered to search. Further, while counsel assumed that an in-person legal visit scheduled for
Saturday, November 21, would be canceled as a result of Ms. Maxwell’s quarantine status, no
notification was provided; and a request for a substituted legal call was not accommodated.
isolation cell during quarantine, an unidentified man entered to take photographs and a guard
entered to search. Further, while counsel assumed that an in-person legal visit scheduled for
Saturday, November 21, would be canceled as a result of Ms. Maxwell’s quarantine status, no
notification was provided; and a request for a substituted legal call was not accommodated.
DOJ-OGR-00001839
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