MDC
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This page from a Government sentencing memorandum (Case 1:20-cr-00330-PAE) argues that Ghislaine Maxwell received preferential treatment at the MDC, including private amenities and access to counsel, refuting her claims of harsh conditions. It highlights inconsistencies in her complaints regarding general population and COVID-19 restrictions. A footnote addresses a 'credible death threat' claim, revealing it was merely an inmate's hypothetical remark about killing Maxwell for a million dollars, which an investigation deemed not credible.
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This document is a Government filing addressing Ghislaine Maxwell's complaints regarding her confinement conditions at the MDC. It refutes claims about discovery access, clarifying that she was provided a laptop and ample attorney visits. It also addresses email deletions (attributing them to BOP policy or Maxwell's own actions), legal mail delivery, and justifies nighttime flashlight checks as standard safety procedures for all inmates.
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This legal document, filed by the Government on June 22, 2022, argues against the defendant's (Ghislaine Maxwell's) complaints regarding her confinement conditions at the MDC. The prosecution asserts that her claims of abuse are unfounded, as determined by a BOP investigation, and are part of a pattern of dishonesty aimed at garnering public sympathy, citing a November 2021 Daily Mail article as a previous example of this tactic.
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This document is a page from a defense sentencing memorandum filed on June 15, 2022, arguing that Ghislaine Maxwell should receive sentencing credits for harsh pretrial detention conditions. The text portrays Maxwell as a hardworking humanitarian who helped launch the Clinton Global Initiative and founded TerraMar, while characterizing her relationship with Jeffrey Epstein as a singular mistake resulting from vulnerability caused by her father's death.
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This legal document, part of case 1:20-cr-00330-PAE filed on June 15, 2022, argues that the pre-sentence detention conditions of Ms. Maxwell at the MDC constitute cruel and unusual punishment in violation of the Eighth Amendment. The filing claims her treatment is significantly harsher than that of the general prison population and was implemented under specific directives from then-Attorney General William Barr, who was intent on avoiding a repeat of the incident involving Epstein in BOP custody. The document asserts this disparate and punitive treatment was condoned by MDC supervisors and wardens.
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This document is page 28 of a legal filing (Case 1:20-cr-00330-PAE) dated June 15, 2022, arguing that Ghislaine Maxwell's pre-sentence detention conditions were discriminatory and harmful to her mental health. The text details symptoms of depression and trauma allegedly caused by confinement and claims that an MDC psychologist was overruled by directives from Washington, D.C. regarding placing Maxwell on suicide watch despite a lack of suicidal indicators. It also notes her isolation due to COVID restrictions and reliance on prison staff for information.
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This legal document details the allegedly poor and dehumanizing conditions of Ms. Maxwell's pre-trial detention. It argues that inadequate nutrition, sleep deprivation, psychological threats, and significant technical difficulties with discovery materials severely weakened her and thwarted her ability to prepare her defense. The document suggests these conditions were intentionally imposed to satisfy various government and legal parties following Epstein's death.
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This document is a page from a legal filing (Case 1:20-cr-00330-PAE) arguing for a downward variance in Ghislaine Maxwell's sentencing due to unusually harsh pre-sentence confinement. The defense claims Maxwell was held in a 9x7 foot isolation cell for 22 months under unparalleled restrictions specifically to prevent another 'Epstein debacle' and to punish her in Epstein's stead. It also details a lack of due process regarding her transfer to the general population, noting that while other inmates were consulted about her arrival, neither Maxwell nor her counsel were notified.
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This document, identified as part of a Presentence Investigation Report, details a recommendation by Probation on June 9, 2022, for a 240-month imprisonment sentence for Ms. Maxwell, followed by five years of supervised release. It outlines mitigating factors, including her age, philanthropic history with organizations like the Clinton Global Initiative and The TerraMar Project, and her activities during incarceration, such as completing courses and tutoring inmates. The document also notes Ms. Maxwell's intention to appeal her conviction.
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This document is a legal filing (Page 8 of 77) from June 15, 2022, arguing that Ghislaine Maxwell's pre-sentence detention conditions were punitive and politically motivated to restore DOJ/BOP reputations following Jeffrey Epstein's death. It details a specific incident where a fellow inmate claimed she was offered money to strangle Maxwell in her sleep, highlighting the danger Maxwell faces in general population at the MDC.
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This legal document, part of a court filing for Ghislaine Maxwell, argues for her release on bail by highlighting her strong family ties, particularly her loving and supportive relationship with her husband. It explains that her husband did not act as a co-signer on her initial bail application in an effort to protect him from 'ferocious media aggression.' He is now coming forward, concerned about her treatment in detention at the MDC, and is prepared to pledge all of their assets to secure her compliance with bail conditions.
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This document is page 2 of a court filing from June 16, 2021, regarding Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell). It details the conditions of the defendant's confinement at the MDC, specifically highlighting her access to attorney communications (25 hours of VTC per week and weekend in-person visits) and the security measures in place, including soundless camera monitoring and mandatory searches (pat-downs, mouth checks, and strip searches).
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This document is a court transcript from June 15, 2021, in which a judge expresses profound frustration with the inhumane and mismanaged conditions at the MCC and MDC federal prisons in New York. The judge describes the facilities as being 'run by morons' and lurching from crisis to crisis, such as gun smuggling related to Jeffrey Epstein. While addressing an inmate, Ms. Days, the judge states that the conditions she endured were disgusting and inhuman, and wishes they could release her but is legally bound to a sentence of at least five years.
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This document is a page from a court transcript filed on June 15, 2021, in Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell). An attorney is arguing that the conditions at the Metropolitan Correctional Center (MCC) over the prior 14 months have been 'inhumane, cruel and harsh,' comparing them unfavorably to prisons in Mexico or El Salvador. The attorney references a client named Ms. Days and cites Judge Oetken's ruling in U.S. v. Gonzalez to argue for sentencing credit based on these harsh conditions.
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This document is a legal filing from the Law Offices of Bobbi C. Sternheim dated June 15, 2021, detailing complaints regarding the confinement conditions of Ghislaine Maxwell at the MDC. It outlines specific incidents of alleged harassment and obstruction by prison guards, including the reading of privileged legal materials, denial of water, excessive monitoring during legal visits, and technical interference with video conferencing that compromises attorney-client privilege.
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This legal document from May 27, 2021, argues that a renewed motion for Ghislaine Maxwell's release should be denied. It supports Judge Nathan's prior ruling that Maxwell is a flight risk and asserts that no new "compelling" reason has been presented to overturn the decision. The document also details Maxwell's extensive access to legal discovery materials and communication with her attorneys while in custody at the MDC.
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This document is the final page (13 of 13) of a court transcript from Case 1:20-cr-00330-PAE (USA v. Ghislaine Maxwell), filed on August 10, 2022. The dialogue involves Ms. Sternheim (Defense) noting rising COVID rates at the MDC facility, and the Court acknowledging availability (presumably of vaccines or testing) at the MDC before adjourning the session. Ms. Moe represents the government.
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This legal document, filed by the U.S. Attorney for the Southern District of New York, details the security and search procedures for a specific defendant at the Metropolitan Detention Center (MDC). It outlines daily pat-down and cell searches, weekly body scans, and frequent nightly wellness checks, justifying them as necessary for the safety of the institution and the defendant. The document also notes a recent change to reduce searches by relocating the defendant's video conferences with her counsel to within her unit.
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This document is the table of contents for a legal filing on behalf of Ms. Maxwell, dated December 23, 2020, likely related to a bail application. The arguments outlined challenge the government's case by highlighting its reliance on limited witness testimony, asserting Ms. Maxwell's strong ties to the U.S. (including her spouse), her full financial disclosure for a bond, and the low probability of her being a flight risk. The filing also leverages a recent COVID surge at the MDC facility as an additional reason for granting bail.
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This legal document, part of a court filing, is the Government's argument against a defendant's release from the Metropolitan Detention Center (MDC). The Government contends that the MDC has adequately addressed the defendant's complaints regarding diet and security searches, and that its COVID-19 precautions were effective, as the defendant was quarantined and tested negative after a potential exposure. The filing concludes that since the defendant has no underlying health conditions, the pandemic does not warrant her release.
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This document is a page from a Government court filing (Case 1:20-cr-00330-AJN, likely USA v. Maxwell) dated December 18, 2020. It addresses defense complaints regarding discovery access, noting that one hard drive malfunctioned because the defendant dropped it, and details her special confinement conditions at the MDC, which include 13 hours out of cell, private shower, computers, phone, and TV. A footnote highlights a contradiction in the defense's arguments regarding the value of discovery versus the prejudice caused by delays.
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This legal document, filed by the Government, refutes the defense's claim that the defendant cannot adequately prepare for trial while detained at the MDC. The Government outlines the measures taken to ensure access to discovery materials and legal counsel, including providing hard drives, a dedicated laptop, and arranging for daily video calls with her lawyer. The document argues that these provisions, despite pandemic-related restrictions, are sufficient for trial preparation.
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This legal document is a filing by the Government arguing for the continued detention of a defendant, asserting she is an extreme flight risk. The Government cites her foreign citizenship in a non-extraditing country, substantial international ties, financial resources, and a demonstrated sophistication in hiding assets. The filing also refutes the defendant's complaints about her conditions of confinement, stating she has ample access to her legal counsel and discovery materials.
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This document is page 38 of a legal filing (filed Jan 21, 2021) arguing for Ghislaine Maxwell's release on bail. The text highlights the difficulties of preparing a defense due to COVID-19 lockdowns at the MDC, citing a spike in cases in early December. The conclusion asserts Maxwell's commitment to fighting the charges, staying in New York, and protecting her sureties, urging the court to grant bail on strict conditions.
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This document is page 35 of a legal filing (Document 102) dated December 14, 2020, arguing for Ghislaine Maxwell's release on bail. The defense asserts she is not a flight risk and argues that her current detention at the MDC constitutes 'de facto solitary confinement' under conditions rivaling a Supermax prison, which impairs her ability to prepare her defense. The text cites United States v. Orta regarding bail standards and claims wardens have noted the unprecedented nature of her restrictive regime.
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