MDC
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This document is Page 2 of a Government filing (Case 1:20-cr-00330-PAE, filed 10/15/21) addressing defense complaints regarding legal mail delays at the MDC. The Government argues that a request for 1-day mail turnaround is burdensome given the facility houses 1,700 inmates. It details the timeline of a specific hard drive delivery: sent Oct 11, received Oct 12, delayed Oct 13 due to an 'institutional emergency,' and personally delivered to the defendant by MDC legal counsel on Oct 14, 2021.
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This document is a page from a government legal filing (Case 21-58) responding to Ghislaine Maxwell's complaints regarding her incarceration conditions at the MDC. The text refutes Maxwell's claims of sewage flooding by clarifying that the cited precedent (Tiffany Days) occurred at the MCC, not the MDC. Additionally, it counters her claim of 'solitary confinement' by detailing her 13-hour daily access to a day room equipped with computers, a phone, and a TV, while noting she requires protective custody for her safety.
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This legal document is a filing by the Government in response to an appeal by Maxwell regarding her pretrial confinement conditions. The Government argues that Maxwell's complaints about disruptive nighttime flashlight checks are unsubstantiated and do not demonstrably interfere with her trial preparation. The document also refutes Maxwell's accusations of misrepresentation, clarifying a statement made by Government counsel and explaining an acknowledged inaccuracy in information received from the MDC.
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This legal document is a page from a court order denying a renewed motion by an individual named Maxwell for temporary release from confinement. The court relies on the 'law of the case' doctrine, stating that Maxwell has not provided a compelling reason, such as new evidence or a change in law, to justify reversing its prior decision. The court also dismisses Maxwell's arguments concerning a recent letter briefing and a written order by Judge Nathan, affirming the previous finding that Maxwell is a flight risk.
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This legal document, part of a court filing, argues that a 'renewed motion' from a defendant named Maxwell is meritless. It cites legal precedents (United States v. Hochevar, Stack v. Boyle) and procedural rules to assert that the motion is not properly before the court. The document further states that a lower court judge, Judge Nathan, did not err in previously finding three times that Maxwell is a flight risk and denying bail.
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This page from a legal filing (Case 21-58) discusses the court's affirmation of Judge Nathan's decision to deny Ghislaine Maxwell bail. The text argues that MDC's nighttime security protocols do not interfere with Maxwell's trial preparation and notes procedural errors in Maxwell's filing of a 'renewed motion' rather than a new appeal or proper motion in District Court. It cites Federal Rules of Appellate Procedure regarding the untimeliness of the motion.
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This page from a legal filing (Case 21-58) argues that Ghislaine Maxwell's motion should be denied. It details Judge Nathan's previous findings that MDC's security protocols—specifically regarding night monitoring and eye coverings—do not interfere with Maxwell's trial preparation. The document affirms that previous denials of bail and release have been upheld.
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This document is page 11 of a court filing dated May 27, 2021, concerning Ghislaine Maxwell's confinement conditions at the Metropolitan Detention Center (MDC). It details the Government's response regarding Maxwell's request for an eye mask and a dispute over nighttime flashlight checks. Judge Nathan denied Maxwell's request to modify the monitoring schedule on May 14, 2021, noting that Maxwell's claims were unsupported by an affidavit and that flashlight checks are standard procedure for all inmates.
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This document page, part of a legal filing from May 2021, details the Government's response to Judge Nathan regarding 'flashlight surveillance' of Ghislaine Maxwell at the MDC. It explains that while general population inmates are checked hourly and SHU inmates every 30 minutes, Maxwell is checked every 15 minutes due to an 'enhanced security schedule' and 'heightened safety and security concerns,' despite not being on suicide watch.
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This legal document outlines the procedural history of a case involving a defendant named Maxwell. After Maxwell appealed two of Judge Nathan's bail decisions and was denied pretrial release on April 27, 2021, she did not file a renewed motion. Instead, on April 29, 2021, she submitted a letter to Judge Nathan requesting the court to order the MDC to stop or justify the 15-minute light surveillance that was disrupting her sleep.
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This legal document, filed on April 29, 2021, is a letter from attorney Bobbi C. Sternheim to the Court regarding her client, Ms. Maxwell, an inmate at the MDC. Sternheim argues against the MDC's threat to move Maxwell to the Special Housing Unit (SHU), claiming she needs protection from staff, not other inmates. The letter also formally requests the Court to order the MDC to stop the disruptive 15-minute flashlight surveillance of Maxwell while she sleeps.
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This document is page 8 of a legal filing (Case 21-58) dated May 17, 2021, arguing against the mistreatment of Ms. Maxwell, specifically regarding sleep deprivation and accusations about hygiene. The defense argues that the government misrepresented facts by claiming Maxwell caused a smell in her cell by not flushing, while the defense asserts the smell was due to MDC infrastructure issues. This claim is supported by testimony from another inmate, Tiffany Days, who described a 'feces flood' at the facility.
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This legal document argues that the government misrepresented information to the court regarding the treatment of inmate Ms. Maxwell. The government initially claimed that flashlight checks every 15 minutes were a routine procedure, but later admitted in a letter that Ms. Maxwell is the only inmate subjected to this treatment. The document contends this is a form of mistreatment being justified without proper evidence, such as an affidavit.
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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.
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This document is page 4 of a legal filing by the Law Offices of Bobbi C. Sternheim on behalf of Ghislaine Maxwell, filed on April 7, 2021. It details complaints regarding Maxwell's confinement conditions at the MDC, including delayed legal mail, unreadable discovery discs, moldy food, sleep deprivation due to lighting and flashlight checks, and 'de facto solitary confinement.' The filing also argues that inadequate computer access hinders her ability to review millions of pages of discovery for her defense.
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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.
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This document is page 2 of a legal filing by attorney Bobbi C. Sternheim regarding the detention conditions of Ghislaine Maxwell at the MDC East Building. The text details unsanitary conditions involving mold and vermin, inadequate facilities for legal counsel meetings (described as a 'fishbowl' and 'death trap'), and Maxwell's deteriorating health due to lack of fresh air and sunlight over eight months. It also notes that a request for a legal call regarding pretrial motions was denied.
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A legal letter from attorney Bobbi C. Sternheim to Judge Alison J. Nathan regarding United States v. Ghislaine Maxwell. The letter refutes the government's claims about Maxwell's detention conditions, arguing they are overly restrictive and punitive. It details unsanitary conditions at the MDC, specifically a recent incident involving a severe sewage stench, overflowing toilets from the floor above, and plumbing issues in Maxwell's isolation cell.
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This legal document is a letter from attorney Bobbi C. Sternheim to the court, filed on April 7, 2021, concerning her client, Ms. Maxwell. Sternheim argues that the government's public updates on Maxwell's confinement conditions are detrimental, fueling negative media attention and jeopardizing her right to a fair trial. The letter requests that any future updates be limited in scope and filed under seal to protect Ms. Maxwell's privacy.
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This document is page 4 of a legal filing by attorney Bobbi C. Sternheim regarding the confinement conditions of Ghislaine Maxwell at the MDC. It details complaints including delayed mail, unreadable discovery discs, moldy food, sleep deprivation due to constant lighting and flashlight checks, and 'de facto solitary confinement.' The filing also argues that inadequate computer equipment is hindering Maxwell's ability to prepare for trial given the massive amount of discovery documents.
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This is page 3 of a legal filing by defense attorney Bobbi C. Sternheim regarding Ghislaine Maxwell. The document alleges that the MDC violated HIPAA by releasing Maxwell's medical info, describes her deteriorating physical condition (failing eyesight, thinning hair), and details an incident where she was physically abused (shoved) by a guard while being moved to 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 claims exists but the defense believes was not recorded.
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This is a letter dated April 7, 2021, from attorney Bobbi C. Sternheim to Judge Alison J. Nathan regarding the case of United States v. Ghislaine Maxwell. The letter strongly objects to the conditions of Ms. Maxwell's pretrial detention at the MDC, describing them as a form of "'pay-it-forward' punishment." It details a recent incident involving a pervasive sewage stench in her unit and argues that the government's portrayal of her confinement as superior is inaccurate and misses the point of her overly restrictive and unwarranted detention.
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This document is page 5 of a legal filing (Case 1:20-cr-00330-PAE) dated April 6, 2021, addressing the confinement conditions of the defendant (Ghislaine Maxwell). It details that her meals are heated in thermal ovens and defends the quality of tap water at the MDC, noting that staff drink the same water and bottled water is provided during maintenance. The filing also reports on the defendant's health, stating she is weighed weekly (fluctuating between 130s and 140s lbs), has a normal BMI, has not experienced hair loss, and is fully vaccinated against COVID-19.
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This document is page 3 of a court filing (Case 1:20-cr-00330-PAE) dated April 6, 2021, detailing the detention conditions of a female defendant (Ghislaine Maxwell) at the MDC. It confirms the defendant is fully vaccinated against COVID-19 and communicates with counsel via VTC and email, as counsel has declined in-person visits. The text also describes security protocols, including daily pat-down searches during movement between the isolation cell and day room, as well as weekly body scans.
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This document is page 2 of a legal filing from April 6, 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 that she is separated from her isolation cell from 7am to 8pm daily with access to electronics and showers. The text extensively describes the protocols for attorney-client communications, noting she receives 25 hours of private VTC calls per week, and clarifies that surveillance cameras monitor the door but do not record the audio or visual content of these legal meetings.
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