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616 KB

Extraction Summary

2
People
2
Organizations
1
Locations
2
Events
2
Relationships
5
Quotes

Document Information

Type: Legal filing / court document (appellate brief or motion)
File Size: 616 KB
Summary

This document serves as the 'Issues Presented' section of a legal filing dated April 1, 2021, related to Case 21-58. It outlines two main arguments: 1) Ms. Maxwell cannot prepare her defense due to horrific detention conditions (sleep deprivation, isolation, surveillance, inadequate technology for discovery review, and poor sustenance), and 2) The trial court erred in denying bail based on 'anonymous, unconfronted, hearsay accusations' provided by the government.

People (2)

Name Role Context
Ms. Maxwell Defendant/Appellant
Subject of the document; arguing that detention conditions prevent effective defense preparation.
Lawyers Defense Counsel
Mentioned in the context of Ms. Maxwell being unable to see them regularly in person.

Organizations (2)

Name Type Context
Trial Court
Accused of erring by relying on government proffers to refuse bail.
Government
Provided the proffer used to deny bail.

Timeline (2 events)

2021-04-01
Filing of legal document outlining issues presented regarding Maxwell's detention conditions and bail refusal.
Court of Appeals (implied by Case 21-58 format)
Ms. Maxwell Defense Counsel
Ongoing (during detention)
Alleged mistreatment including sleep deprivation, constant surveillance, and lack of food/water.
Detention Facility

Locations (1)

Location Context
Location where Ms. Maxwell is held in 'de facto solitary confinement' and 'horrific conditions'.

Relationships (2)

Ms. Maxwell Adversarial Government
Document challenges the government's proffer used to deny bail.
Ms. Maxwell Judicial Trial Court
Document questions whether the trial court erred in its decision making regarding bail.

Key Quotes (5)

"Whether Ms. Maxwell can effectively prepare her defense where she is being subjected to horrific conditions of detention during a global pandemic"
Source
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Quote #1
"being kept awake all night to make sure she does not commit suicide even though nothing suggests she is a suicide risk"
Source
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Quote #2
"being stuck in de facto solitary confinement without safe, in person visitation"
Source
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Quote #3
"not consistently provided edible food or drinkable water"
Source
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Quote #4
"Whether the trial court erred by relying on the government’s proffer — which was comprised of nothing but extremely old, anonymous, unconfronted, hearsay accusations — to refuse to set reasonable bail."
Source
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Quote #5

Full Extracted Text

Complete text extracted from the document (1,275 characters)

Case 21-58, Document 39-1, 04/01/2021, 3068530, Page6 of 31
ISSUES PRESENTED
1. Whether Ms. Maxwell can effectively prepare her defense where she is being subjected to horrific conditions of detention during a global pandemic, including:
• not being able to regularly see her lawyers in person to prepare for trial;
• being kept awake all night to make sure she does not commit suicide even though nothing suggests she is a suicide risk;
• having her every movement videotaped on multiple cameras focused on her every move;
• being stuck in de facto solitary confinement without safe, in person visitation;
• being forced to review millions of pages of documents on a stripped down computer without adequate hardware or software such that Ms. Maxwell cannot open tens of thousands of pages of discovery and for those she can open, only has the ability to review them one page at a time and cannot search, edit, copy, or print;
• having no writing surface in her solitary cell; and
• not consistently provided edible food or drinkable water.
2. Whether the trial court erred by relying on the government’s proffer — which was comprised of nothing but extremely old, anonymous, unconfronted, hearsay accusations — to refuse to set reasonable bail.
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DOJ-OGR-00019834

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