DOJ-OGR-00001345.jpg
981 KB
Extraction Summary
3
People
4
Organizations
4
Locations
4
Events
3
Relationships
0
Quotes
Document Information
Type:
Legal document
File Size:
981 KB
Summary
This legal document is a joint letter dated December 1, 2020, from the prosecution and defense to Judge Alison J. Nathan in the case of United States v. Ghislaine Maxwell. The letter details a disagreement between the two parties regarding how to address the defendant's concerns about her conditions of confinement at the Metropolitan Detention Center (MDC). The Government proposes a written response from MDC's legal counsel, while the defense insists on a personal court appearance by the warden, Heriberto Tellez.
People (3)
| Name | Role | Context |
|---|---|---|
| Alison J. Nathan | Judge, United States District Court |
The letter is addressed to 'The Honorable Alison J. Nathan' and refers to her as 'Judge Nathan'.
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| Ghislaine Maxwell | Defendant |
The defendant in the case 'United States v. Ghislaine Maxwell'. The letter discusses her conditions of detention.
|
| Heriberto Tellez | Warden, Metropolitan Detention Center |
Mentioned as 'MDC Warden Heriberto Tellez'. The defense requests his appearance in court to address Ms. Maxwell's con...
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| U.S. Department of Justice | government agency |
Appears in the letterhead of the document.
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| United States Attorney, Southern District of New York | government agency |
The sender of the letter, representing the Government in the case.
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| United States District Court, Southern District of New York | government agency |
The court where Judge Alison J. Nathan presides and where the case is being heard.
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| Metropolitan Detention Center | government agency |
Referred to as 'MDC', it is the facility where the defendant, Ghislaine Maxwell, is being detained.
|
Timeline (4 events)
2020-10-29
The defense emailed a letter to Warden Tellez detailing concerns about Ghislaine Maxwell's onerous and restrictive conditions of confinement.
Defense counsel
Heriberto Tellez
2020-11-23
The Government submitted a letter regarding the defendant's access to legal materials and counsel.
United States District Court, Southern District of New York
Government counsel
2020-11-24
The Court issued an order directing the parties to meet and confer regarding the defendant's request about her conditions of detention.
United States District Court, Southern District of New York
week prior to 2020-12-01
The Government conferred with defense counsel three times regarding the defendant's conditions of confinement and the defense's request relating to the warden.
Government counsel
Defense counsel
Locations (4)
| Location | Context |
|---|---|
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The jurisdiction of the United States Attorney and the United States District Court mentioned in the document.
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The address of the United States Attorney's office.
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The address of the United States District Court.
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The facility where the defendant is being held.
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Relationships (3)
The document is a filing in the criminal case 'United States v. Ghislaine Maxwell', establishing an adversarial relationship between the prosecutor (Government) and the defendant.
Government Counsel
→
professional
→
Defense Counsel
The letter states that the parties (Government and defense) have conferred multiple times but 'have been unable to reach agreement' on how to proceed, indicating a professional but adversarial relationship.
The defense, on behalf of Maxwell, has raised concerns about her conditions of confinement under Warden Tellez and is requesting he appear in court to address them.
Full Extracted Text
Complete text extracted from the document (2,975 characters)
Case: 20-cr-00330-AJN Document 78 Filed 12/01/20 Page 1 of 2
U.S. Department of Justice
United States Attorney
Southern District of New York
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew’s Plaza
New York, New York 10007
One Saint Andrew’s Plaza
New York, New York 10007
December 1, 2020
BY ECF
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
United States Courthouse
40 Foley Square
New York, New York 10007
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
United States Courthouse
40 Foley Square
New York, New York 10007
Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan:
The parties jointly submit this letter in response to the Court’s November 24, 2020 order directing the parties to meet and confer regarding the defendant’s request that the warden of the Metropolitan Detention Center (“MDC”) report directly to the Court and counsel on the defendant’s conditions of detention. (Dkt. No. 76). Over the past week, the Government has spoken with MDC legal counsel regarding the defendant’s conditions of confinement and has tried to gather additional information regarding the concerns raised by the defendant, which the Government has shared with defense counsel. The Government has also conferred with defense counsel three times regarding the same, as well as the defense’s request relating to MDC Warden Heriberto Tellez. The parties have been unable to reach agreement. Our respective positions follow.
The Government respectfully submits that the Court should allow MDC legal counsel to respond directly in writing to the Court and defense counsel regarding the concerns defense counsel has raised relating to the defendant’s conditions of confinement. The Government understands that MDC legal counsel is prepared to submit a letter by this Friday, December 4, 2020. Such a letter is the appropriate next step at this time, as it will allow the Court to hear directly from MDC legal counsel who can address the defendant’s conditions of confinement. The letter will allow the Court to ascertain whether further inquiry, including a personal appearance by the Warden or other MDC personnel, is necessary. Moreover, the Government does not understand the concerns raised by the defense to implicate the defendant’s access to legal materials or her ability to communicate with her counsel. As noted in the Government’s letter dated November 23, 2020, the defendant continues to have more time to review her discovery than any other inmate at the MDC. The defendant also has as much, if not more, time as any other MDC inmate to communicate with her attorneys. (Dkt. No. 74).
The defense disagrees. As communicated to the Government, the defense’s position is as follows: Warden Heriberto Tellez should appear before the Court to directly address concerns regarding Ms. Maxwell’s conditions of confinement, which specifically target her. On October 29, 2020, the defense emailed a letter to Warden Tellez detailing the onerous and restrictive conditions, including but not limited to concerns regarding the supplemental camera; excessive
DOJ-OGR-00001345
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