DOJ-OGR-00001176.jpg
818 KB
Extraction Summary
3
People
3
Organizations
1
Locations
2
Events
1
Relationships
3
Quotes
Document Information
Type:
Legal filing (government response/brief)
File Size:
818 KB
Summary
This page from a government legal filing addresses defense complaints regarding discovery access and confinement conditions. The government asserts that a hard drive malfunction was caused by the defendant dropping it and that she currently has full access to materials. It also defends her confinement conditions at the MDC, detailing privileges such as 13 hours out of cell daily, private shower, computer access, and television, arguing these are superior to general population conditions.
People (3)
| Name | Role | Context |
|---|---|---|
| The Defendant | Defendant/Inmate |
Ghislaine Maxwell (implied by Case 1:20-cr-00330). Accused of dropping a hard drive; subject of confinement condition...
|
| IT staff | Technical Support |
Government staff offered to review a malfunctioning drive.
|
| MDC legal counsel | Legal Counsel |
Counsel for the detention center working with the Government regarding defendant's access.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| The Government |
Prosecution/DOJ
|
|
| The Defense |
Legal team for the defendant
|
|
| MDC |
Metropolitan Detention Center (place of confinement)
|
Timeline (2 events)
2020-12-18 (approximate)
Government preparing a backup copy of all discovery productions on a single drive.
N/A
Prior to 2020-12-18
Locations (1)
| Location | Context |
|---|---|
|
Metropolitan Detention Center, where the defendant is detained.
|
Relationships (1)
The Government will continue to work with MDC legal counsel to ensure that the defendant is able to review her discovery
Key Quotes (3)
"the malfunctioning of the sixth production that the defense complains of resulted from the defendant herself dropping the hard drive onto the ground"Source
DOJ-OGR-00001176.jpg
Quote #1
"the defendant is released from her isolation cell for thirteen hours per day, has her own shower, has exclusive use of two different computers, has her own phone to use, and has her own television."Source
DOJ-OGR-00001176.jpg
Quote #2
"Those conditions set her far apart from general population inmates"Source
DOJ-OGR-00001176.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (2,441 characters)
Case 1:20-cr-00330-AJN Document 100 Filed 12/18/20 Page 34 of 36
As to the defense’s most recent complaints, the malfunctioning of the sixth production that
the defense complains of resulted from the defendant herself dropping the hard drive onto the
ground, and that drive has been replaced. When the defense informed the Government that the
drive containing the seventh production may be malfunctioning, the Government offered to have
IT staff review the drive. In response, the defense indicated the drive was in fact still viewable
and declined to have IT staff review it. Accordingly, it is the Government’s understanding that
the defendant currently has a full, readable set of discovery at the MDC. At the defense’s request,
the Government is preparing yet another copy containing all productions to date on a single drive
so that the defendant will have a backup copy of discovery materials at the MDC.11 Throughout
the defendant’s pretrial detention, the Government has been responsive to the defense’s concerns
regarding access to discovery and counsel. The Government will continue to work with MDC
legal counsel to ensure that the defendant is able to review her discovery and to communicate with
defense counsel over the seven months still remaining before trial.
the defense complains of resulted from the defendant herself dropping the hard drive onto the
ground, and that drive has been replaced. When the defense informed the Government that the
drive containing the seventh production may be malfunctioning, the Government offered to have
IT staff review the drive. In response, the defense indicated the drive was in fact still viewable
and declined to have IT staff review it. Accordingly, it is the Government’s understanding that
the defendant currently has a full, readable set of discovery at the MDC. At the defense’s request,
the Government is preparing yet another copy containing all productions to date on a single drive
so that the defendant will have a backup copy of discovery materials at the MDC.11 Throughout
the defendant’s pretrial detention, the Government has been responsive to the defense’s concerns
regarding access to discovery and counsel. The Government will continue to work with MDC
legal counsel to ensure that the defendant is able to review her discovery and to communicate with
defense counsel over the seven months still remaining before trial.
As to the defense complaints regarding the defendant’s conditions of confinement, the
defense notably does not suggest that the defendant should be housed in general population.
Indeed, the defense appears to agree that the best way to ensure the defendant’s safety while
detained is to be away from general population. Unlike other inmates in protective custody,
however, the defendant is released from her isolation cell for thirteen hours per day, has her own
shower, has exclusive use of two different computers, has her own phone to use, and has her own
television. Those conditions set her far apart from general population inmates, not to mention
defense notably does not suggest that the defendant should be housed in general population.
Indeed, the defense appears to agree that the best way to ensure the defendant’s safety while
detained is to be away from general population. Unlike other inmates in protective custody,
however, the defendant is released from her isolation cell for thirteen hours per day, has her own
shower, has exclusive use of two different computers, has her own phone to use, and has her own
television. Those conditions set her far apart from general population inmates, not to mention
11 On this score, the Government notes the tension between the defense claim that the discovery
produced to date contains little of value or relevant to the charges set forth in the Indictment, and
the simultaneous claim that the defendant has been prejudiced by technical difficulties that have
temporarily delayed her ability to review portions of those productions, productions which,
according to the defense, counsel have already been able to conclude are essentially unimportant.
produced to date contains little of value or relevant to the charges set forth in the Indictment, and
the simultaneous claim that the defendant has been prejudiced by technical difficulties that have
temporarily delayed her ability to review portions of those productions, productions which,
according to the defense, counsel have already been able to conclude are essentially unimportant.
31
DOJ-OGR-00001176
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