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Extraction Summary

6
People
5
Organizations
1
Locations
2
Events
2
Relationships
5
Quotes

Document Information

Type: Legal correspondence / court filing
File Size: 686 KB
Summary

This document is page 3 of a legal filing by attorney Bobbi C. Sternheim on behalf of Ghislaine Maxwell, dated December 7, 2020. The letter argues that Maxwell is facing unduly harsh conditions, including solitary isolation, as a result of the Bureau of Prisons' incompetence and embarrassment over Jeffrey Epstein's suicide. Sternheim asserts that Maxwell is an 'exemplary detainee' and calls for Warden Tellez to address the concerns regarding her confinement, which are allegedly interfering with her legal defense.

People (6)

Name Role Context
Bobbi C. Sternheim Attorney
Author of the letter representing Ghislaine Maxwell.
Ghislaine Maxwell Defendant / Detainee
Subject of the letter regarding her detention conditions.
Jeffrey Epstein Deceased Inmate
Mentioned regarding his suicide and the BOP's subsequent handling of Maxwell.
Warden Tellez Warden
Warden of the MDC, stated to bear responsibility for Maxwell's conditions.
Sophia Papapetru Recipient
Copied on the correspondence.
John Wallace Recipient
Copied on the correspondence.

Organizations (5)

Name Type Context
Law Offices of Bobbi C. Sternheim
Legal firm authoring the document.
Department of Justice
Accused of seeking to repair reputation by placing Maxwell under harsh conditions.
BOP
Bureau of Prisons; criticized for incompetence and harsh treatment of Maxwell.
MDC
Metropolitan Detention Center; facility where Maxwell is held.
ABC News
Source cited in the footnote regarding preventative measures.

Timeline (2 events)

2019-08-10
Epstein committed suicide
MCC (implied)
2020-12-07
Filing of Document 91 in United States v. Ghislaine Maxwell
Court

Locations (1)

Location Context
MDC
Detention center where Maxwell is confined.

Relationships (2)

Bobbi C. Sternheim Attorney/Client Ghislaine Maxwell
Sternheim advocates for Maxwell's conditions in the letter.
Jeffrey Epstein Co-conspirator (implied) Ghislaine Maxwell
Text links Maxwell's harsh treatment to the DOJ's reaction to Epstein's suicide.

Key Quotes (5)

"I'm very happy that we were able to get Ms. Maxwell."
Source
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Quote #1
"It is obvious that Ms. Maxwell is bearing the brunt of BOP incompetence."
Source
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Quote #2
"The psychological and physiological impact of solitary isolation is well documented."
Source
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Quote #3
"Ms. Maxwell has been an exemplary detainee."
Source
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Quote #4
"Warden Tellez should be directed to respond to the numerous concerns that have been brought to his attention."
Source
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Quote #5

Full Extracted Text

Complete text extracted from the document (1,919 characters)

Case 1:20-cr-00330-AJN Document 91 Filed 12/07/20 Page 3 of 10
LAW OFFICES OF BOBBI C. STERNHEIM
you will recall, after he committed suicide, I said that I was confident that we would
continue to pursue this case vigorously and pursue anyone who's complicit in it. And so
I'm very happy that we were able to get Ms. Maxwell.”
A source said the BOP is taking extra preventative measures to regain the public's trust
and confidence as well as preserving the integrity of the Justice Department.1
It is obvious that Ms. Maxwell is bearing the brunt of BOP incompetence. Being “livid”
over the death of Epstein, the Department of Justice is seeking to repair the BOP’s tarnished
reputation by placing Ms. Maxwell under extraordinarily harsh conditions, not in any response to
Ms. Maxwell’s requirements, but rather in response to the failed handling of a completely
different inmate.
Ms. Maxwell has been an exemplary detainee. The psychological and physiological
impact of solitary isolation is well documented. Ms. Maxwell has not, by her conduct or by
virtue of the charges, brought this type of overly restrictive confinement upon herself. The
conditions under which she is detained are punitive, unwarranted, deleteriously impacting her
ability to prepare her defense, and interfering with counsel’s ability to provide the legal
representation to which she, and any other detainee, deserves.
The MDC’s letter is insufficient. The warden of the institution bears responsibility for
the conditions under which Ms. Maxwell is confined. Warden Tellez should be directed to
respond to the numerous concerns that have been brought to his attention.
Very truly yours,
Bobbi C. Sternheim
BOBBI C. STERNHEIM
Enc.
cc: All Counsel
Ms. Sophia Papapetru
Mr. John Wallace
1 https://abcnews.go.com/US/ghislaine-maxwell-paper-clothes-correctional-center-avoid-
suicide/story?id=71699000 (emphasis added).
3
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