DOJ-OGR-00001399.jpg
721 KB
Extraction Summary
5
People
4
Organizations
3
Locations
2
Events
2
Relationships
5
Quotes
Document Information
Type:
Legal filing / letter from defense counsel
File Size:
721 KB
Summary
This document is page 2 of a legal filing by attorney Bobbi C. Sternheim regarding the confinement conditions of Ghislaine Maxwell at the MDC. The letter details severe sanitary issues including mold, vermin, and undrinkable tap water, as well as restrictive legal visitation conditions that impede attorney-client privilege. It also notes Maxwell's deteriorating health and lack of access to fresh air for eight months.
People (5)
| Name | Role | Context |
|---|---|---|
| Bobbi C. Sternheim | Defense Attorney |
Author of the letter, representing Ms. Maxwell
|
| Ghislaine Maxwell | Defendant / Inmate |
Subject of the letter, described as living in squalor and deteriorating health at MDC
|
| HVAC inspector | Inspector |
Characterized the legal visiting rooms as a 'death trap'
|
| Guards | Prison Staff |
Accused of using cleaning as punishment, drinking bottled water instead of tap, and constantly surveilling legal visits
|
| Medical staff | Medical Personnel |
Monitoring Ms. Maxwell's health and recording her weight
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| Law Offices of Bobbi C. Sternheim |
Header of the document
|
|
| MDC |
Metropolitan Detention Center, specifically the East Building where Maxwell is held
|
|
| Government |
Addressed in the letter regarding water quality
|
|
| DOJ |
Department of Justice (referenced in footer stamp DOJ-OGR)
|
Timeline (2 events)
2020-08 to 2021-04
Ms. Maxwell has not experienced sunshine and fresh air for the past eight months
MDC
Ongoing
Legal visits characterized by uncomfortable conditions, lack of privacy, and surveillance
MDC Legal Visiting Rooms
Locations (3)
| Location | Context |
|---|---|
|
Where Ms. Maxwell is held, described as permeated with mold and vermin
|
|
|
Described as a 'fishbowl' and 'death trap'
|
|
|
Exercise area described as a misnomer for 'outside'
|
Relationships (2)
Letter written by Sternheim advocating for Maxwell regarding prison conditions.
Guards use cleaning as punishment; guards surveil visits; guards refuse to share weight data.
Key Quotes (5)
"regularly, I challenge the government to identify anyone that would risk their health by drinking the tap water."Source
DOJ-OGR-00001399.jpg
Quote #1
"The MDC - especially the East Building where Ms. Maxwell is held– is permeated with mold and vermin."Source
DOJ-OGR-00001399.jpg
Quote #2
"Cockroaches and rodents are plentiful and glue tracks have been placed in Ms. Maxwell’s day area"Source
DOJ-OGR-00001399.jpg
Quote #3
"characterized by an HVAC inspector as 'a death trap'"Source
DOJ-OGR-00001399.jpg
Quote #4
"Ms. Maxwell’s health is deteriorating. She has not experienced sunshine and fresh air for the past eight months."Source
DOJ-OGR-00001399.jpg
Quote #5
Full Extracted Text
Complete text extracted from the document (2,042 characters)
Case 1:20-cr-00330-AJN Document 197 Filed 04/07/21 Page 2 of 5
LAW OFFICES OF BOBBI C. STERNHEIM
LAW OFFICES OF BOBBI C. STERNHEIM
regularly, I challenge the government to identify anyone that would risk their health by drinking
the tap water. Even the guards resort to drinking bottled water.
the tap water. Even the guards resort to drinking bottled water.
Blaming Ms. Maxwell for the filth of her severely restricted environment is utterly
misplaced. To suggest she willingly lives in squalor is absurd. In an effort to wield power, the
guards use cleaning as a punishment. The MDC - especially the East Building where Ms.
Maxwell is held– is permeated with mold and vermin. Cockroaches and rodents are plentiful and
glue tracks have been placed in Ms. Maxwell’s day area to help remediate the problem.
misplaced. To suggest she willingly lives in squalor is absurd. In an effort to wield power, the
guards use cleaning as a punishment. The MDC - especially the East Building where Ms.
Maxwell is held– is permeated with mold and vermin. Cockroaches and rodents are plentiful and
glue tracks have been placed in Ms. Maxwell’s day area to help remediate the problem.
While HEPA filters may improve the safety of the legal visiting rooms – characterized by
an HVAC inspector as “a death trap” – in-person visiting with Ms. Maxwell is uncomfortable
and unproductive. Relegated to a small “fishbowl” where chairs abut glass walls and a table,
with no room in between, Ms. Maxwell and counsel are forced to wedge their bodies into chairs.
There is no opportunity to view electronic discovery or exchange documents; and speaking while
wearing a face mask while crammed on either side of a plexiglass divider under surveillance of
three guards and a handheld camera places a chill on any free exchange of confidential
information. While video conferencing has facilitated on-going communication between Ms.
Maxwell and counsel, her request for a legal call to confer with counsel regarding pretrial
motions was denied.
an HVAC inspector as “a death trap” – in-person visiting with Ms. Maxwell is uncomfortable
and unproductive. Relegated to a small “fishbowl” where chairs abut glass walls and a table,
with no room in between, Ms. Maxwell and counsel are forced to wedge their bodies into chairs.
There is no opportunity to view electronic discovery or exchange documents; and speaking while
wearing a face mask while crammed on either side of a plexiglass divider under surveillance of
three guards and a handheld camera places a chill on any free exchange of confidential
information. While video conferencing has facilitated on-going communication between Ms.
Maxwell and counsel, her request for a legal call to confer with counsel regarding pretrial
motions was denied.
Ms. Maxwell’s health is deteriorating. She has not experienced sunshine and fresh air for
the past eight months. Referring to an interior gated pen where Ms. Maxwell can exercise (and
be subjected to even more searches) as the “outside” is a misnomer. Barely a breeze permeates
that area.
the past eight months. Referring to an interior gated pen where Ms. Maxwell can exercise (and
be subjected to even more searches) as the “outside” is a misnomer. Barely a breeze permeates
that area.
Medical staff monitor Ms. Maxwell’s health by recording her weight in her medical
chart. Guards declined Ms. Maxwell’s request to know her weight, claiming they cannot look it
chart. Guards declined Ms. Maxwell’s request to know her weight, claiming they cannot look it
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