DOJ-OGR-00000913.jpg
626 KB
Extraction Summary
2
People
2
Organizations
1
Locations
3
Events
1
Relationships
5
Quotes
Document Information
Type:
Legal motion / court filing (appellate brief)
File Size:
626 KB
Summary
This document is a page from Ghislaine Maxwell's motion for pretrial release, dated April 1, 2021. It details her complaints regarding harsh detention conditions, including sleep deprivation, intrusive searches, and isolation, which she argues prevent her from effectively preparing for trial. It also highlights logistical difficulties in reviewing 2.5 million pages of discovery material on a limited computer via video link with her attorneys.
People (2)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Appellant / Defendant |
Subject of the motion requesting pretrial release due to detention conditions.
|
| Trial Lawyers | Legal Counsel |
Mentioned as communicating with Maxwell via video screen due to pandemic risks.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| Department of Justice |
Inferred from footer stamp 'DOJ-OGR'.
|
|
| US Court of Appeals |
Implied by 'Appellant' and Case number format.
|
Timeline (3 events)
Ongoing
Sleep deprivation tactics (awakened every 15 minutes by flashlights)
Detention Facility
Ghislaine Maxwell
Guards
Ongoing
Locations (1)
| Location | Context |
|---|---|
|
Described as a 'squalid facility' where Maxwell has been held for over 280 days.
|
Relationships (1)
Ms. Maxwell sees her trial lawyers over a video screen
Key Quotes (5)
"For over 280 days, she has been held in the equivalent of solitary confinement"Source
DOJ-OGR-00000913.jpg
Quote #1
"intentionally awakened every 15 minutes by lights shined directly into her small cell"Source
DOJ-OGR-00000913.jpg
Quote #2
"intrusive searches, including having hands forced into her mouth"Source
DOJ-OGR-00000913.jpg
Quote #3
"she must review over 2,500,000 prosecution pages on a gutted computer, which does not have the ability to search, edit, or print"Source
DOJ-OGR-00000913.jpg
Quote #4
"review one page of the discovery at a time that is projected on a wall three feet away"Source
DOJ-OGR-00000913.jpg
Quote #5
Full Extracted Text
Complete text extracted from the document (1,300 characters)
Case 21-770, Document 20-1, 04/01/2021, 3068530, Page3 of 31
Appellant Ghislaine Maxwell’s Motion for Pretrial Release
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 over 280 days, 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 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. The medical literature is unanimous that such conditions produce mental deterioration, which prevents her from effective participation in trial preparation.
Worse, even if Ms. Maxwell were able to be fully alert and mentally acute, she must review over 2,500,000 prosecution pages on a gutted computer, which does not have the ability to search, edit, or print. Because of the pandemic, in-person lawyer visits are risky, so Ms. Maxwell sees her trial lawyers over a video screen, where she can review one page of the discovery at a time that is projected on a wall three feet away.
1
DOJ-OGR-00000913
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