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632 KB

Extraction Summary

3
People
4
Organizations
2
Locations
2
Events
2
Relationships
5
Quotes

Document Information

Type: Legal motion / appellate filing
File Size: 632 KB
Summary

This document is page 4 of a legal filing (Case 21-58) dated May 17, 2021, arguing for Ghislaine Maxwell's release on bond due to 'horrific conditions' at the MDC. The text details specific grievances, including sleep deprivation by guards every 15 minutes, contaminated brown water, sewage smells in her unit, and the video/audio recording of privileged meetings with her attorneys. The filing asserts that these conditions make it impossible for her to prepare for trial and that she is not being treated like similarly situated pre-trial detainees.

People (3)

Name Role Context
Ghislaine Maxwell Defendant/Detainee
Subject of the motion, describing her prison conditions and seeking bond.
District Court Judge Judge
Issued previous orders regarding Maxwell's treatment (implied).
Guards Prison Staff
Accused of waking Maxwell every 15 minutes and recording attorney-client meetings.

Organizations (4)

Name Type Context
Bureau of Prisons
Federal agency overseeing the MDC.
MDC
Metropolitan Detention Center, where Maxwell is being held.
The Government
Prosecution/DOJ.
DOJ
Department of Justice (referenced in footer OGR stamp).

Timeline (2 events)

2021-05-17
Renewal of motion for bond and relief from court.
Court
Defense Team Court
Ongoing
Sleep deprivation checks (every 15 minutes).
MDC

Locations (2)

Location Context
MDC
Metropolitan Detention Center (Prison).
Specific cell/area where sewage issues are reported.

Relationships (2)

Ghislaine Maxwell Custodial/Adversarial Guards
Guards wake her every 15 minutes and record her legal meetings.
Ghislaine Maxwell Attorney-Client Lawyers
Attempts to meet in person are hindered by surveillance.

Key Quotes (5)

"Ms. Maxwell is not being treated like any other detainee."
Source
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Quote #1
"the horrific conditions make it impossible to prepare for trial."
Source
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Quote #2
"we renew our motion for bond and seek relief from this Court."
Source
DOJ-OGR-00020328.jpg
Quote #3
"guards use a handheld camera to video and audio tape record the meetings"
Source
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Quote #4
"can’t drink the water because it is brown and contains particles"
Source
DOJ-OGR-00020328.jpg
Quote #5

Full Extracted Text

Complete text extracted from the document (1,327 characters)

Case 21-58, Document 89-1, 05/17/2021, 3102450, Page4 of 14
of sleep would alleviate her stress instead of exacerbate it. Ms. Maxwell
replied. Ex. E, Doc. 272.
The district court then issued an order saying that it would not tell
the Bureau of Prisons what to do but “admonishe[d] the MDC and the
Government to continue to ensure that Maxwell is subjected to only those
security protocols that BOP determines are necessary for her safety and
security, based upon neutral and applicable factors, and consistent with
the treatment of similarly situated pre-trial detainees.” Ex. B, Doc. 282.
But Ms. Maxwell is not being treated like any other detainee. And
the horrific conditions make it impossible to prepare for trial.
Accordingly, we renew our motion for bond and seek relief from this
Court. Ms. Maxwell simply wants a fair opportunity to fight the charges
against her at trial.
Currently, she (1) can’t sleep because the guards wake her every 15
minutes; (2) oftentimes can’t drink the water because it is brown and
contains particles; (3) can’t meet in person with her lawyers because the
guards use a handheld camera to video and audio tape record the
meetings; (4) can’t manage the smell of overflowing sewage that comes
up from the drain in her unit; (5) can’t keep the guards from seizing and
2
DOJ-OGR-00020328

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