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721 KB

Extraction Summary

5
People
4
Organizations
3
Locations
2
Events
2
Relationships
6
Quotes

Document Information

Type: Legal correspondence / court filing (page 2 of 5)
File Size: 721 KB
Summary

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.

People (5)

Name Role Context
Ghislaine Maxwell Defendant/Detainee
Subject of the letter describing poor detention conditions, health deterioration, and lack of access to counsel.
Bobbi C. Sternheim Defense Attorney
Author of the document (indicated by letterhead), advocating for Maxwell.
Guards Prison Staff
Accused of using cleaning as punishment, drinking bottled water instead of tap, conducting surveillance, and refusing...
HVAC Inspector Inspector
Characterized the legal visiting rooms as a 'death trap'.
Medical Staff Prison Medical Personnel
Monitoring 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
Challenged by the author regarding tap water safety.
DOJ
Referenced in the footer stamp (DOJ-OGR).

Timeline (2 events)

2021-04-07
Document filed with the court.
Court (Case 1:20-cr-00330-AJN)
Past eight months (relative to April 2021)
Period during which Maxwell has not experienced sunshine or fresh air.
MDC

Locations (3)

Location Context
Specific location where Maxwell is held, described as permeated with mold and vermin.
Described as a 'fishbowl', uncomfortable, unproductive, and a 'death trap' regarding HVAC.
Exercise area, described as not truly 'outside'.

Relationships (2)

Bobbi C. Sternheim Attorney-Client Ghislaine Maxwell
Letterhead and content advocating for Maxwell's conditions.
Guards Custodial/Adversarial Ghislaine Maxwell
Guards use cleaning as punishment, surveillance, refusal to provide weight information.

Key Quotes (6)

"regularly, I challenge the government to identify anyone that would risk their health by drinking the tap water."
Source
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Quote #1
"To suggest she willingly lives in squalor is absurd."
Source
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Quote #2
"The MDC - especially the East Building where Ms. Maxwell is held– is permeated with mold and vermin."
Source
DOJ-OGR-00020317.jpg
Quote #3
"characterized by an HVAC inspector as “a death trap”"
Source
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Quote #4
"Relegated to a small “fishbowl” where chairs abut glass walls"
Source
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Quote #5
"She has not experienced sunshine and fresh air for the past eight months."
Source
DOJ-OGR-00020317.jpg
Quote #6

Full Extracted Text

Complete text extracted from the document (2,045 characters)

Case 1:20-cr-00330-AJN Document 197-1 Filed 04/07/21 Page 2 of 5
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.
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.
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.
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.
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
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DOJ-OGR-00020317

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