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866 KB
Extraction Summary
3
People
6
Organizations
3
Locations
3
Events
2
Relationships
6
Quotes
Document Information
Type:
Legal correspondence / court filing
File Size:
866 KB
Summary
This is the second page of a legal filing by attorney Bobbi C. Sternheim on behalf of Ghislaine Maxwell, dated November 24, 2020. The letter complains to the Court about the harsh conditions of Maxwell's pretrial detention at the MDC, describing them as worse than those for terrorists at ADMAX, citing sleep deprivation via flashlight checks every 15 minutes, excessive surveillance, and isolation. Sternheim requests that Warden Heriberto Tellez be summoned to report directly to the Court regarding these conditions and notes the difficulty Maxwell faces in reviewing 1.2 million discovery documents under her current restrictions.
People (3)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant / Pretrial Detainee |
Subject of the letter regarding her detention conditions at MDC.
|
| Bobbi C. Sternheim | Defense Attorney |
Author of the letter, representing Maxwell.
|
| Heriberto Tellez | Warden |
Warden of MDC whom the defense requests be summoned to report to the Court.
|
Organizations (6)
| Name | Type | Context |
|---|---|---|
| Law Offices of Bobbi C. Sternheim |
Legal firm representing the defendant.
|
|
| MDC |
Metropolitan Detention Center, where Maxwell is detained.
|
|
| MCC |
Metropolitan Correctional Center, used for comparison regarding restrictive units.
|
|
| BOP |
Bureau of Prisons.
|
|
| FCI Florence ADMAX |
Supermax prison used for comparison regarding restrictive conditions.
|
|
| The Government |
Prosecution team.
|
Timeline (3 events)
Recent (relative to 2020-11-24)
Locations (3)
| Location | Context |
|---|---|
|
Detention facility housing Maxwell.
|
|
|
Restrictive unit in the MCC.
|
|
|
Federal prison in Colorado.
|
Relationships (2)
Sternheim writes on behalf of Maxwell as her counsel.
Tellez is the Warden of the facility where Maxwell is detained.
Key Quotes (6)
"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."Source
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Quote #1
"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 #2
"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 #3
"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."Source
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Quote #4
"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."Source
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Quote #5
"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."Source
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Quote #6
Full Extracted Text
Complete text extracted from the document (2,605 characters)
Case 1:20-cr-00330-AJN Document 75 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
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