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735 KB
Extraction Summary
3
People
5
Organizations
2
Locations
2
Events
2
Relationships
6
Quotes
Document Information
Type:
Legal filing / court document (defense letter)
File Size:
735 KB
Summary
This is page 3 of a legal filing by defense attorney Bobbi C. Sternheim regarding Ghislaine Maxwell. The document alleges that the MDC violated HIPAA by releasing Maxwell's medical info, describes her deteriorating physical condition (failing eyesight, thinning hair), and details an incident where she was physically abused (shoved) by a guard while being moved to an isolation cell. The defense requests the Court order the MDC to stop releasing health info and demands video evidence of the abuse incident, which the government claims exists but the defense believes was not recorded.
People (3)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant / Inmate |
Subject of the letter regarding her confinement conditions, health, and alleged abuse at MDC.
|
| Bobbi C. Sternheim | Defense Attorney |
Author of the document (Law Offices of Bobbi C. Sternheim).
|
| AJN | Judge |
Referenced in Case Number (Alison J. Nathan), addressed as 'Your Honor'.
|
Organizations (5)
| Name | Type | Context |
|---|---|---|
| Law Offices of Bobbi C. Sternheim | ||
| MDC |
Metropolitan Detention Center; accused of violating HIPAA and housing abusive guards.
|
|
| MDC Legal |
Recipient of previous report regarding physical abuse.
|
|
| The Court |
Entity being petitioned to order MDC to stop releasing health info and provide video evidence.
|
|
| DOJ |
Department of Justice (referenced in footer stamp).
|
Timeline (2 events)
Prior to 2021-04-07
Locations (2)
| Location | Context |
|---|---|
|
Metropolitan Detention Center (implied location of confinement).
|
|
|
Location within the facility where Ms. Maxwell was allegedly shoved.
|
Relationships (2)
Letterhead 'Law Offices of Bobbi C. Sternheim' writing on behalf of Ms. Maxwell.
Description of guards weighing her and one guard shoving her.
Key Quotes (6)
"Her eyesight is failing, and her hair is thinning."Source
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Quote #1
"The incident of physical abuse which occurred when Ms. Maxwell was shoved into her isolation cell to be searched was previously reported to MDC Legal..."Source
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Quote #2
"The guard responsible for the abuse is a member of a rotating team that has been the subject of complaint..."Source
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Quote #3
"On information and belief, the camera was not recording at that time."Source
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Quote #4
"By releasing such information regarding Ms. Maxwell, the MDC has violated HIPAA..."Source
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Quote #5
"We request that the Court direct the government to provide defense counsel with that video."Source
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Quote #6
Full Extracted Text
Complete text extracted from the document (2,146 characters)
Case 1:20-cr-00330-AJN Document 197 Filed 04/07/21 Page 3 of 5
LAW OFFICES OF BOBBI C. STERNHEIM
LAW OFFICES OF BOBBI C. STERNHEIM
up because it is part of her medical record, which is protected by the American Health Insurance
Portability and Accountability Act Health Information Policy (HIPAA). She is weighed while
clothed on scales that are erratic and not set to zero; on at least one occasion, the scale was set
above five pounds. Her eyesight is failing, and her hair is thinning. The guards are far from
qualified to assess Ms. Maxwell’s physical condition.
Portability and Accountability Act Health Information Policy (HIPAA). She is weighed while
clothed on scales that are erratic and not set to zero; on at least one occasion, the scale was set
above five pounds. Her eyesight is failing, and her hair is thinning. The guards are far from
qualified to assess Ms. Maxwell’s physical condition.
Releasing any inmate’s medical information (i.e., weight, vaccinations, etc.) without
inmate consent is a HIPAA violation. By releasing such information regarding Ms. Maxwell, the
MDC has violated HIPAA, a privacy breach compounded by the government’s letter. Requesting
medical attention puts Ms. Maxwell’s privacy and HIPAA rights at risk. We request that the
Court order the MDC to cease releasing Ms. Maxwell’s health information. Breach aside, such
information falls within the “caution” category identified in Your Honor’s Individual Practice in
Criminal Cases (see 8D (Redactions)). The government, ever protective of sensitive items of
discovery that relate to the alleged victims, should exhibit the same concern for Ms. Maxwell’s
right to privacy.
inmate consent is a HIPAA violation. By releasing such information regarding Ms. Maxwell, the
MDC has violated HIPAA, a privacy breach compounded by the government’s letter. Requesting
medical attention puts Ms. Maxwell’s privacy and HIPAA rights at risk. We request that the
Court order the MDC to cease releasing Ms. Maxwell’s health information. Breach aside, such
information falls within the “caution” category identified in Your Honor’s Individual Practice in
Criminal Cases (see 8D (Redactions)). The government, ever protective of sensitive items of
discovery that relate to the alleged victims, should exhibit the same concern for Ms. Maxwell’s
right to privacy.
The incident of physical abuse which occurred when Ms. Maxwell was shoved into her
isolation cell to be searched was previously reported to MDC Legal and the Court and
investigated within the facility. The guard responsible for the abuse is a member of a rotating
team that has been the subject of complaint, yet some members were reassigned to Ms. Maxwell
for the past two weeks. The incident at issue occurred when Ms. Maxwell was facing forward in
front of an officer whose back was in front of the handheld camera. On information and belief,
the camera was not recording at that time. The government disputes Ms. Maxwell’s claim by
citing a video. We request that the Court direct the government to provide defense counsel with
that video. In response to any misconduct of guards, the standard reply is that “the matter will be
isolation cell to be searched was previously reported to MDC Legal and the Court and
investigated within the facility. The guard responsible for the abuse is a member of a rotating
team that has been the subject of complaint, yet some members were reassigned to Ms. Maxwell
for the past two weeks. The incident at issue occurred when Ms. Maxwell was facing forward in
front of an officer whose back was in front of the handheld camera. On information and belief,
the camera was not recording at that time. The government disputes Ms. Maxwell’s claim by
citing a video. We request that the Court direct the government to provide defense counsel with
that video. In response to any misconduct of guards, the standard reply is that “the matter will be
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DOJ-OGR-00002909
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