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631 KB

Extraction Summary

3
People
3
Organizations
2
Locations
3
Events
1
Relationships
4
Quotes

Document Information

Type: Legal filing / court motion (appeal regarding pretrial detention)
File Size: 631 KB
Summary

This page is from a legal appeal filed on May 17, 2021, arguing for the temporary release of Ghislaine Maxwell on bond. The defense claims her constitutional rights are being violated by 'squalid' pretrial detention conditions, including sleep deprivation (lights every 15 minutes), intrusive searches, and isolation, which prevent her from effectively preparing for trial. The document references a plea by Judge McMahon and cites a separate case (US v. Tiffany Days) as precedent or context.

People (3)

Name Role Context
Ghislaine Maxwell Defendant/Appellant
Subject of the motion; described as suffering in solitary confinement and unable to prepare for trial.
Judge McMahon Judge
Referenced as having 'pleaded' for the Court to take action.
Tiffany Days Defendant in cited case
Mentioned in a case citation (United States v. Tiffany Days) regarding a sentencing hearing transcript.

Organizations (3)

Name Type Context
United States Government
Opposing party in the 'adversary system'; accused of making false representations about confinement conditions.
Department of Justice (DOJ)
Indicated by the Bates stamp 'DOJ-OGR'.
The Court
The entity being appealed to for intervention.

Timeline (3 events)

2020-2021
Pretrial detention of Ghislaine Maxwell (described as 'almost a year').
Detention Facility
April 29, 2021
Sentencing hearing for United States v. Tiffany Days.
Court
May 17, 2021
Filing date of the document.
Court Record

Locations (2)

Location Context
Description of the detention center where Maxwell is held (likely MDC Brooklyn, though not named explicitly).
Maxwell's specific confinement location.

Relationships (1)

Ghislaine Maxwell Adversarial The Government
Text states 'This is an adversary system' and notes they will not agree on facts.

Key Quotes (4)

"Ghislaine Maxwell has a Constitutional right to be able to prepare effectively for trial."
Source
DOJ-OGR-00020336.jpg
Quote #1
"For almost a year, she has been held in the equivalent of solitary confinement, in deteriorating health and mental condition from lack of sleep because she is intentionally awakened every 15 minutes..."
Source
DOJ-OGR-00020336.jpg
Quote #2
"including having hands forced into her mouth in a squalid facility where COVID has run rampant."
Source
DOJ-OGR-00020336.jpg
Quote #3
"If the Court is not prepared to temporarily release Ms. Maxwell on bond so that she can prepare for trial, it should"
Source
DOJ-OGR-00020336.jpg
Quote #4

Full Extracted Text

Complete text extracted from the document (1,306 characters)

Case 21-58, Document 89-1, 05/17/2021, 3102450, Page12 of 14
something.” See transcript of sentencing hearing, United States v.
Tiffany Days, April 29, 2021, which can be accessed at:
https://tinyurl.com/48yw29px.
We are appealing to this Court to do something, as Judge McMahon
pleaded. Ghislaine Maxwell has a Constitutional right to be able to
prepare effectively for trial. The conditions of her pretrial detention
deprive her of that right. For almost a year, she has been held in the
equivalent of solitary confinement, in deteriorating health and mental
condition from lack of sleep because she is intentionally awakened every
15 minutes by lights shined directly into her small cell, inadequate water
and food, the constant glare of neon light, and intrusive searches,
including having hands forced into her mouth in a squalid facility where
COVID has run rampant.
Ms. Maxwell understands that she and the government are not
going to agree on the facts. This is an adversary system, of course. But
when the government’s representations about the conditions of
confinement continue to be demonstrably and admittedly false, there
needs to be an intervention. If the Court is not prepared to temporarily
release Ms. Maxwell on bond so that she can prepare for trial, it should
10
DOJ-OGR-00020336

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