DOJ-OGR-00010584.jpg
776 KB
Extraction Summary
6
People
3
Organizations
2
Locations
3
Events
3
Relationships
3
Quotes
Document Information
Type:
Court filing (government response/sentencing memorandum)
File Size:
776 KB
Summary
This document is a Government filing addressing Ghislaine Maxwell's complaints regarding her confinement conditions at the MDC. It refutes claims about discovery access, clarifying that she was provided a laptop and ample attorney visits. It also addresses email deletions (attributing them to BOP policy or Maxwell's own actions), legal mail delivery, and justifies nighttime flashlight checks as standard safety procedures for all inmates.
People (6)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Subject of the document, inmate at MDC complaining about conditions of confinement and discovery access.
|
| The Government | Prosecution |
Responding to defendant's complaints and informing the Court.
|
| Defense Counsel/Attorneys | Legal Defense |
Representing Maxwell, reviewing discovery, and lodging complaints.
|
| MDC Legal Counsel | Legal Representative for Prison |
Provided information regarding prison policies (email purging, flashlight checks) and investigated complaints.
|
| MDC Staff | Prison Employees |
Conducted email audits and perform nighttime flashlight checks.
|
| The Court | Judiciary |
Recipient of the filing and information.
|
Timeline (3 events)
During trial
Relationships (3)
defendant’s attorneys had full copies of her discovery and were able to review all discovery material with her
As the Government has previously informed the Court
legal counsel for the MDC has conveyed that...
Key Quotes (3)
"legal counsel for the MDC has conveyed that per BOP policy, all inmate emails are routinely purged every six months."Source
DOJ-OGR-00010584.jpg
Quote #1
"that examination revealed that the defendant had herself deleted some of her emails and had archived others, but it revealed no evidence to suggest that MDC staff deleted any of the defendant’s emails."Source
DOJ-OGR-00010584.jpg
Quote #2
"MDC staff point a flashlight at the ceiling of each cell to illuminate the cell sufficiently to confirm that the inmate is present in the cell, breathing, and not in distress."Source
DOJ-OGR-00010584.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (2,295 characters)
Case 1:20-cr-00330-PAE Document 670 Filed 06/22/22 Page 49 of 55
Additionally, the defendant’s attorneys had full copies of her discovery and were able to
review all discovery material with her during their ample time for attorney visits both by VTC and
in person. The Government also took numerous steps to address the defendant’s complaints about
unreadable files within her discovery, including by providing a laptop (in addition to the BOP-
provided desktop computer) on which to review her discovery, providing new copies of discovery,
and conferring with defense counsel regarding specific files the defendant had difficulty viewing.
As the Government has previously informed the Court in response to the defendant’s allegations
regarding her emails, legal counsel for the MDC has conveyed that per BOP policy, all inmate
emails are routinely purged every six months. In response to complaints from the defense
regarding prematurely deleted emails, MDC staff examined the defendant’s inmate email account.
According to legal counsel for the MDC, that examination revealed that the defendant had herself
deleted some of her emails and had archived others, but it revealed no evidence to suggest that
MDC staff deleted any of the defendant’s emails. As the Government has previously informed the
Court in response to the defendant’s complaints about delivery of mail, Maxwell’s legal mail was
processed and delivered to her in the same manner as mail for other inmates at the MDC. During
trial, MDC legal counsel permitted the Government to bring hard drives and disks containing legal
materials to court and Maxwell was permitted to bring those materials back with her to the MDC.
review all discovery material with her during their ample time for attorney visits both by VTC and
in person. The Government also took numerous steps to address the defendant’s complaints about
unreadable files within her discovery, including by providing a laptop (in addition to the BOP-
provided desktop computer) on which to review her discovery, providing new copies of discovery,
and conferring with defense counsel regarding specific files the defendant had difficulty viewing.
As the Government has previously informed the Court in response to the defendant’s allegations
regarding her emails, legal counsel for the MDC has conveyed that per BOP policy, all inmate
emails are routinely purged every six months. In response to complaints from the defense
regarding prematurely deleted emails, MDC staff examined the defendant’s inmate email account.
According to legal counsel for the MDC, that examination revealed that the defendant had herself
deleted some of her emails and had archived others, but it revealed no evidence to suggest that
MDC staff deleted any of the defendant’s emails. As the Government has previously informed the
Court in response to the defendant’s complaints about delivery of mail, Maxwell’s legal mail was
processed and delivered to her in the same manner as mail for other inmates at the MDC. During
trial, MDC legal counsel permitted the Government to bring hard drives and disks containing legal
materials to court and Maxwell was permitted to bring those materials back with her to the MDC.
As the Government has previously informed the Court in response to the defendant’s
complaints regarding nighttime checks, legal counsel for the MDC had indicated that staff conduct
flashlight checks at night for all inmates as a matter of course throughout the facility for the safety
and security of the inmates at the institution. During these flashlight checks, MDC staff point a
flashlight at the ceiling of each cell to illuminate the cell sufficiently to confirm that the inmate is
present in the cell, breathing, and not in distress. Legal counsel for the MDC has explained that
complaints regarding nighttime checks, legal counsel for the MDC had indicated that staff conduct
flashlight checks at night for all inmates as a matter of course throughout the facility for the safety
and security of the inmates at the institution. During these flashlight checks, MDC staff point a
flashlight at the ceiling of each cell to illuminate the cell sufficiently to confirm that the inmate is
present in the cell, breathing, and not in distress. Legal counsel for the MDC has explained that
47
DOJ-OGR-00010584
Discussion 0
No comments yet
Be the first to share your thoughts on this epstein document