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744 KB
Extraction Summary
4
People
4
Organizations
2
Locations
2
Events
2
Relationships
5
Quotes
Document Information
Type:
Legal correspondence / court filing
File Size:
744 KB
Summary
This document is page 3 of a legal filing by attorney Bobbi C. Sternheim regarding the confinement conditions of Ghislaine Maxwell at the MDC. The letter alleges HIPAA violations regarding the release of Maxwell's medical data and details an incident of physical abuse where a guard shoved Maxwell into 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 disputes.
People (4)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant/Inmate |
Subject of the letter; described as having failing eyesight, thinning hair, and being the victim of physical abuse by...
|
| Bobbi C. Sternheim | Defense Counsel |
Author of the document (indicated by letterhead).
|
| Unnamed Guards | Correctional Officers |
Accused of physical abuse (shoving Maxwell), being unqualified to assess physical condition, and improper use of came...
|
| The Court / Your Honor | Judge |
Recipient of the request to order MDC to stop releasing health info and to provide video evidence.
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| Law Offices of Bobbi C. Sternheim | Legal Firm |
Defense counsel firm.
|
| MDC | Correctional Facility |
Metropolitan Detention Center; accused of HIPAA violations and employing abusive guards.
|
| The Government | Prosecution |
Disputes Maxwell's claims citing video; accused of compounding privacy breaches.
|
| MDC Legal | Legal Department |
Internal department previously notified of the abuse incident.
|
Timeline (2 events)
Unknown (Prior to 2021-03-07)
Locations (2)
| Location | Context |
|---|---|
|
Place of confinement.
|
|
|
Specific location where physical abuse allegedly occurred.
|
Relationships (2)
Allegation that guard shoved Maxwell into isolation cell.
Government disputes Maxwell's claim by citing a video.
Key Quotes (5)
"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
"On information and belief, the camera was not recording at that time."Source
DOJ-OGR-00020318.jpg
Quote #3
"By releasing such information regarding Ms. Maxwell, the MDC has violated HIPAA"Source
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Quote #4
"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."Source
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Quote #5
Full Extracted Text
Complete text extracted from the document (2,146 characters)
Case 1:20-cr-00330-AJN Document 217 Filed 03/07/21 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
3
DOJ-OGR-00020318
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