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1.04 MB
Extraction Summary
4
People
4
Organizations
1
Locations
3
Events
1
Relationships
4
Quotes
Document Information
Type:
Legal filing / court document (defense counsel letter)
File Size:
1.04 MB
Summary
This legal filing from December 2020 outlines complaints regarding the conditions of Ghislaine Maxwell's confinement at the MDC. The defense argues she is being deprived of communication with family and legal counsel, citing specific issues such as deleted legal emails, physical barriers during visits, denial of basic needs during meetings, and the intentional damaging of a hard drive by an officer. The document concludes that these restrictions are arbitrary and disproportionate, noting Maxwell's good behavior and certifications as a suicide counselor and teacher.
People (4)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant/Detainee |
Subject of the document; complaining of poor confinement conditions and interference with legal counsel.
|
| Bobbi C. Sternheim | Defense Attorney |
Author of the document (implied by letterhead 'LAW OFFICES OF BOBBI C. STERNHEIM').
|
| Federal Defenders | Legal Organization |
Mentioned as confirming legal calls that were subsequently denied.
|
| Guards/Officers | Prison Staff |
Accused of mishandling evidence, recording legal visits, and enforcing harsh restrictions.
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| Law Offices of Bobbi C. Sternheim |
Legal firm representing Maxwell.
|
|
| MDC |
Metropolitan Detention Center; the facility where Maxwell is held.
|
|
| Federal Defenders |
Legal organization.
|
|
| CorrLinks |
Email system used by inmates.
|
Timeline (3 events)
Ongoing
Legal conferences where Maxwell is separated by a cloudy plastic shield, cannot handle documents, and is denied food/water/toilet use.
MDC Visiting Room
Ghislaine Maxwell
Counsel
Ongoing
Guards setting up a tripod/camera focused on Maxwell during legal conferences.
MDC
Week prior to 2020-12-07
An officer delivering a hard drive appeared to intentionally let it fall to the ground, damaging the device.
MDC
Ghislaine Maxwell
Unnamed Officer
Locations (1)
| Location | Context |
|---|---|
|
Metropolitan Detention Center (prison facility).
|
Relationships (1)
Letterhead and content regarding 'counsel'.
Key Quotes (4)
"All of Ms. Maxwell’s CorrLinks emails – all legal correspondence between Ms. Maxwell and counsel - have been deleted, well before the 180-day period in which they may be purged."Source
DOJ-OGR-00001874.jpg
Quote #1
"the officer delivering a hard drive last week appeared to intentionally let it fall to the ground, damaging to the device."Source
DOJ-OGR-00001874.jpg
Quote #2
"Ironically, she has achieved two of the highest certifications offered at the MDC: suicide counselor and teacher/instructor."Source
DOJ-OGR-00001874.jpg
Quote #3
"When counsel inquired why the camera was being focused on the legal conference, the officer responded that Ms. Maxwell must be watched at all times."Source
DOJ-OGR-00001874.jpg
Quote #4
Full Extracted Text
Complete text extracted from the document (3,377 characters)
Case 1:20-cr-00330-AJN Document 91 Filed 12/07/20 Page 9 of 10
LAW OFFICES OF BOBBI C. STERNHEIM
LAW OFFICES OF BOBBI C. STERNHEIM
Deprivation of Communication with Family and Friends: The impact of Ms.
Maxwell’s solitary confinement is aggravated by the deprivation of communication with friends
and family. She was limited in the number of familial and social calls to a degree far less than
any other detainee of which we are aware; and far less than even those who have been convicted
of crimes and held in the same facility.
Maxwell’s solitary confinement is aggravated by the deprivation of communication with friends
and family. She was limited in the number of familial and social calls to a degree far less than
any other detainee of which we are aware; and far less than even those who have been convicted
of crimes and held in the same facility.
Compromised Communication with Legal Counsel: As a consequence of COVID-19,
restrictions have been placed on exercise of attorney-client relationship for all inmates but
seemingly more so for Ms. Maxwell. Scheduled calls have been mishandled by the institution,
resulting in missed legal calls. Despite numerous requests, only one video conference has been
scheduled for Ms. Maxwell during the entirety of her detention. Recently, legal calls have been
repeatedly denied even when confirmed by the Federal Defenders.
restrictions have been placed on exercise of attorney-client relationship for all inmates but
seemingly more so for Ms. Maxwell. Scheduled calls have been mishandled by the institution,
resulting in missed legal calls. Despite numerous requests, only one video conference has been
scheduled for Ms. Maxwell during the entirety of her detention. Recently, legal calls have been
repeatedly denied even when confirmed by the Federal Defenders.
All of Ms. Maxwell’s CorrLinks emails – all legal correspondence between Ms. Maxwell
and counsel - have been deleted, well before the 180-day period in which they may be purged.
During in-person legal conferences, Ms. Maxwell has not been permitted to physically handle
and review legal documents provided by counsel. Rather, counsel must hold each page against
the plastic partition requiring Ms. Maxwell to read these documents, at times from a distance of
approximately four feet through a cloudy plastic shield. This method of discovery review in a
case involving hundreds of thousands of documents consumes the majority of a time-limited
legal conference. It is painstakingly slow and, often, impossible.
and counsel - have been deleted, well before the 180-day period in which they may be purged.
During in-person legal conferences, Ms. Maxwell has not been permitted to physically handle
and review legal documents provided by counsel. Rather, counsel must hold each page against
the plastic partition requiring Ms. Maxwell to read these documents, at times from a distance of
approximately four feet through a cloudy plastic shield. This method of discovery review in a
case involving hundreds of thousands of documents consumes the majority of a time-limited
legal conference. It is painstakingly slow and, often, impossible.
Additionally, Ms. Maxwell is denied water or food and the use of toilet facilities during
legal visits. She has been told that if she uses the toilet, the conference will be suspended while
she is searched, returned to her unit, and then brought back to the visiting room. This process is
time-consuming and limits the duration of the legal conference.
legal visits. She has been told that if she uses the toilet, the conference will be suspended while
she is searched, returned to her unit, and then brought back to the visiting room. This process is
time-consuming and limits the duration of the legal conference.
In advance of each meeting, officers review her legal materials, slowly and deliberately,
and appear to be reading content and breaching confidentiality of privileged information rather
than conducting a routine security check. In addition to experiencing difficulty reviewing
electronic discovery because files do not open, the officer delivering a hard drive last week
appeared to intentionally let it fall to the ground, damaging to the device.
and appear to be reading content and breaching confidentiality of privileged information rather
than conducting a routine security check. In addition to experiencing difficulty reviewing
electronic discovery because files do not open, the officer delivering a hard drive last week
appeared to intentionally let it fall to the ground, damaging to the device.
While meeting with counsel, guards set up a tripod with a camera focused on Ms.
Maxwell during the entirety of the legal conference. When counsel inquired why the conference
was being recorded, the officer claimed the camera was not recording. When counsel inquired
why the camera was being focused on the legal conference, the officer responded that Ms.
Maxwell must be watched at all times.
Maxwell during the entirety of the legal conference. When counsel inquired why the conference
was being recorded, the officer claimed the camera was not recording. When counsel inquired
why the camera was being focused on the legal conference, the officer responded that Ms.
Maxwell must be watched at all times.
Conclusion
These arbitrary and onerous restrictions imposed on Ms. Maxwell are contrary to prison
rules and protocols, are not imposed on other inmates, and are utterly disproportionate to her
detention. At no time has Ms. Maxwell been deemed a threat to herself or others or posed any
disciplinary issues. Ironically, she has achieved two of the highest certifications offered at the
MDC: suicide counselor and teacher/instructor.
rules and protocols, are not imposed on other inmates, and are utterly disproportionate to her
detention. At no time has Ms. Maxwell been deemed a threat to herself or others or posed any
disciplinary issues. Ironically, she has achieved two of the highest certifications offered at the
MDC: suicide counselor and teacher/instructor.
5
DOJ-OGR-00001874
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