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845 KB
Extraction Summary
3
People
4
Organizations
1
Locations
2
Events
2
Relationships
4
Quotes
Document Information
Type:
Legal filing / court brief (page 19 of 24)
File Size:
845 KB
Summary
This document is page 19 of a legal filing (Case 21-770) dated May 27, 2021, addressing Ghislaine Maxwell's appeal regarding pretrial release and confinement conditions. The text argues that Maxwell failed to prove MDC security protocols interfere with her trial preparation and addresses specific disputes regarding 'nighttime checks' with flashlights and the use of eye coverings. A lengthy footnote clarifies a previous inaccuracy regarding Maxwell's use of an eye mask and defends the Government against accusations of misrepresentation.
People (3)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant/Appellant |
Subject of confinement conditions; appealing regarding pretrial release and preparation for trial.
|
| Judge Nathan | District Court Judge |
Recipient of communications from the Government regarding MDC protocols.
|
| Government counsel | Prosecution/Respondent |
Made statements at oral argument regarding routine checks; clarified knowledge about inmate procedures.
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| MDC |
Metropolitan Detention Center; facility where Maxwell is held; provided information to Government regarding protocols.
|
|
| Government |
The prosecution; responding to Maxwell's complaints and conveying information from MDC.
|
|
| District Court |
The lower court where applications regarding trial preparation should be made.
|
|
| This Court |
The appellate court reviewing the current motion (implied by Case 21-770 header).
|
Timeline (2 events)
2021-05-27
Locations (1)
| Location | Context |
|---|---|
|
Detention center where confinement conditions (flashlight checks) are occurring.
|
Relationships (2)
Maxwell is confined at MDC and subject to security protocols like nighttime flashlight checks.
MDC provides information to the Government, which the Government then conveys to the Court (sometimes correcting inaccuracies).
Key Quotes (4)
"nighttime checks involve shining a flashlight directly into her eyes (as opposed to the ceiling)"Source
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Quote #1
"Maxwell availed herself of that process, but in so doing offered no evidence that the MDC’s security protocols are unjustified or interfering with her preparation for trial."Source
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Quote #2
"I can’t speak to what is done as to all inmates."Source
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Quote #3
"The Government has and will continue to accurately represent the information it receives from the MDC"Source
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Quote #4
Full Extracted Text
Complete text extracted from the document (2,111 characters)
Case 21-770, Document 73, 05/27/2021, 3109708, Page19 of 24
nighttime checks involve shining a flashlight directly into her eyes (as opposed to
the ceiling), that the checks in fact disturb her sleep, or that the checks prevent her
from being able to prepare her defense.³
the ceiling), that the checks in fact disturb her sleep, or that the checks prevent her
from being able to prepare her defense.³
36. It bears emphasis that Maxwell’s appeal ostensibly concerns a
motion for pretrial release, such that the conditions of her confinement are relevant
only insofar as they affect her ability to prepare for trial. As this Court previously
recognized, the appropriate avenue for Maxwell to raise concerns about her ability
to prepare for trial is through an application to the District Court. Maxwell availed
herself of that process, but in so doing offered no evidence that the MDC’s security
protocols are unjustified or interfering with her preparation for trial. Tellingly,
motion for pretrial release, such that the conditions of her confinement are relevant
only insofar as they affect her ability to prepare for trial. As this Court previously
recognized, the appropriate avenue for Maxwell to raise concerns about her ability
to prepare for trial is through an application to the District Court. Maxwell availed
herself of that process, but in so doing offered no evidence that the MDC’s security
protocols are unjustified or interfering with her preparation for trial. Tellingly,
³ Maxwell repeatedly accuses the Government of making misrepresentations during
the course of this case. It is correct that the MDC informed the Government that
Maxwell wore an eye mask at night, when in fact she uses other non-contraband
items to cover her eyes. The Government conveyed the MDC’s imprecise language
in an April 6, 2021 letter to Judge Nathan but has since recognized and
acknowledged the inaccuracy. The remaining accusations, however, are
unfounded. For example, Maxwell takes Government counsel’s statement at oral
argument about nighttime checks being “routine” out of context when claiming that
it involved some representation that all inmates experience flashlight checks every
15 minutes. To the contrary, when asked whether the nighttime checks were
conducted at that interval for every inmate, Government counsel clarified, “I can’t
speak to what is done as to all inmates.” Only after conferring with the MDC did
the Government convey to Judge Nathan, and now this Court, the MDC’s procedures
for nighttime checks of all inmates. The Government has and will continue to
accurately represent the information it receives from the MDC when necessary to
respond to Maxwell’s complaints or inquiries from the Court.
19
the course of this case. It is correct that the MDC informed the Government that
Maxwell wore an eye mask at night, when in fact she uses other non-contraband
items to cover her eyes. The Government conveyed the MDC’s imprecise language
in an April 6, 2021 letter to Judge Nathan but has since recognized and
acknowledged the inaccuracy. The remaining accusations, however, are
unfounded. For example, Maxwell takes Government counsel’s statement at oral
argument about nighttime checks being “routine” out of context when claiming that
it involved some representation that all inmates experience flashlight checks every
15 minutes. To the contrary, when asked whether the nighttime checks were
conducted at that interval for every inmate, Government counsel clarified, “I can’t
speak to what is done as to all inmates.” Only after conferring with the MDC did
the Government convey to Judge Nathan, and now this Court, the MDC’s procedures
for nighttime checks of all inmates. The Government has and will continue to
accurately represent the information it receives from the MDC when necessary to
respond to Maxwell’s complaints or inquiries from the Court.
19
DOJ-OGR-00001459
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