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802 KB
Extraction Summary
4
People
4
Organizations
3
Locations
3
Events
2
Relationships
4
Quotes
Document Information
Type:
Court filing (government sentencing memorandum/response)
File Size:
802 KB
Summary
This page from a Government sentencing memorandum (Case 1:20-cr-00330-PAE) argues that Ghislaine Maxwell received preferential treatment at the MDC, including private amenities and access to counsel, refuting her claims of harsh conditions. It highlights inconsistencies in her complaints regarding general population and COVID-19 restrictions. A footnote addresses a 'credible death threat' claim, revealing it was merely an inmate's hypothetical remark about killing Maxwell for a million dollars, which an investigation deemed not credible.
People (4)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Referred to as 'the defendant' and 'Maxwell' (in footnote). Subject of the sentencing arguments regarding confinement...
|
| Unidentified Inmate | Inmate at MDC |
Made a remark about killing Maxwell for money; was investigated and moved out of the housing unit.
|
| Unidentified Witness | Inmate/Observer |
Overheard the threat remark and reported it.
|
| MDC Legal Counsel | Legal Counsel |
Conferred with the Government regarding the death threat investigation and addressed defendant's concerns.
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| MDC |
Metropolitan Detention Center; facility where the defendant was detained.
|
|
| The Government |
Prosecution; conferred with MDC counsel regarding threats.
|
|
| The Court |
Addressed in the filing regarding sentencing.
|
|
| DOJ |
Department of Justice (indicated by footer DOJ-OGR).
|
Timeline (3 events)
2020-2022 (Implied)
COVID-19 lockdowns causing loss of visitation and excessive cell time
MDC
General Population Inmates
Unknown
Locations (3)
| Location | Context |
|---|---|
|
Detention facility where the defendant was held.
|
|
|
Area within the prison the defendant was moved to/from.
|
|
|
Specific location within MDC where the threatening inmate was moved from.
|
Relationships (2)
Defendant brought concerns to MDC legal counsel; received 'exceptional benefits'.
Inmate remarked they would kill Maxwell for a million dollars.
Key Quotes (4)
"If anything, the defendant’s privilege remained intact while at the MDC, as demonstrated by the exceptional benefits she received."Source
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Quote #1
"The defendant had her own shower, her own television, her own desktop computer, her own laptop, and her own space to spend the day outside of her cell."Source
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Quote #2
"“I’d kill her if someone paid me a million dollars.”"Source
DOJ-OGR-00010586.jpg
Quote #3
"The MDC’s investigation revealed that the inmate had not actually been paid to kill the defendant and had not actually threatened Maxwell."Source
DOJ-OGR-00010586.jpg
Quote #4
Full Extracted Text
Complete text extracted from the document (2,420 characters)
Case 1:20-cr-00330-PAE Document 670 Filed 06/22/22 Page 51 of 55
between the defendant’s prior life and the life of an inmate may feel extreme to the defendant, but
when compared to the experiences of other pretrial detainees in this District, her experience is by
no means so shocking as to merit a downward variance.
when compared to the experiences of other pretrial detainees in this District, her experience is by
no means so shocking as to merit a downward variance.
If anything, the defendant’s privilege remained intact while at the MDC, as demonstrated
by the exceptional benefits she received. No other inmate received the kind of access to discovery
and to counsel that the defendant did. The defendant had her own shower, her own television, her
own desktop computer, her own laptop, and her own space to spend the day outside of her cell.
The defendant was able to get any concerns, no matter how small, immediately brought to the
attention of MDC legal counsel through her attorneys. Comparing that treatment to SAMS is out
of touch with reality. In many respects, the defendant’s conditions of confinement were
preferential and more beneficial than those experienced by other inmates.
by the exceptional benefits she received. No other inmate received the kind of access to discovery
and to counsel that the defendant did. The defendant had her own shower, her own television, her
own desktop computer, her own laptop, and her own space to spend the day outside of her cell.
The defendant was able to get any concerns, no matter how small, immediately brought to the
attention of MDC legal counsel through her attorneys. Comparing that treatment to SAMS is out
of touch with reality. In many respects, the defendant’s conditions of confinement were
preferential and more beneficial than those experienced by other inmates.
Tellingly, the defendant’s complaints about the MDC seem internally inconsistent. On the
one hand, she complains that she was removed from general population. On the other hand, she
claims that she should not have been moved abruptly into general population after the conclusion
of her trial.⁹ On the one hand, she claims that she would have had more freedom in general
population. On the other hand, she asks the Court for a lesser sentence because the general
population lost visitation and was locked into their cells for excessive periods because of COVID-
19. On the one hand, she complains that a camera was always on her. On the other hand, she
one hand, she complains that she was removed from general population. On the other hand, she
claims that she should not have been moved abruptly into general population after the conclusion
of her trial.⁹ On the one hand, she claims that she would have had more freedom in general
population. On the other hand, she asks the Court for a lesser sentence because the general
population lost visitation and was locked into their cells for excessive periods because of COVID-
19. On the one hand, she complains that a camera was always on her. On the other hand, she
________
⁹ The defendant also makes the sensational claim that she was the target of a “credible death
threat.” (Dkt. No. 663 at 7). The Government has conferred with legal counsel for the MDC and
has been informed that the MDC conducted an internal investigation of the purported threat and
determined the following: an inmate at the MDC remarked to someone in passing, in sum and
substance, “I’d kill her if someone paid me a million dollars.” Someone else overheard that remark
and reported it, resulting in the inmate being moved out of the housing unit. The MDC’s
investigation revealed that the inmate had not actually been paid to kill the defendant and had not
actually threatened Maxwell.
⁹ The defendant also makes the sensational claim that she was the target of a “credible death
threat.” (Dkt. No. 663 at 7). The Government has conferred with legal counsel for the MDC and
has been informed that the MDC conducted an internal investigation of the purported threat and
determined the following: an inmate at the MDC remarked to someone in passing, in sum and
substance, “I’d kill her if someone paid me a million dollars.” Someone else overheard that remark
and reported it, resulting in the inmate being moved out of the housing unit. The MDC’s
investigation revealed that the inmate had not actually been paid to kill the defendant and had not
actually threatened Maxwell.
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DOJ-OGR-00010586
DOJ-OGR-00010586
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