Case 1:20-cr-00330-AJN Document 91 Filed 12/07/20 Page 1 of 10
LAW OFFICES OF BOBBI C. STERNHEIA
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December 7, 2020
BY ECF
Honorable Alison J. Nathan
United States District Judge
United States Courthouse
40 Foley Square
New York, NY 10007
Re: United States v. Ghislaine Maxwell
20 Cr. 330 (AJN)
Dear Judge Nathan:
As counsel for Ghislaine Maxwell, we write in response to the letter from Sophia
Papapetru and John Wallace, MDC staff attorneys. (See Dkt. 88.) The letter fails to address a
number of concerns raised in our October 29" letter to Warden Heriberto Tellez and raised with
the Court. The MDC’s letter also contains inaccuracies and omissions and raises more questions
than it attempts to answer. Rather than paraphrase our letter, we are providing it for the Court’s
consideration. (See Exhibit A.) We renew our request that Warden Tellez respond directly to
the Court and counsel and explain why Ms. Maxwell must be detained under such harsh and
restrictive conditions.
Using the term “[iJn her current assignment,” the letter attempts to present a picture of
compliance with total disregard of the deficiencies of Ms. Maxwell’s treatment up to this point.
While her meals may currently be in accordance with BOP policy, until September they were
not. While her weight may currently be fairly consistent, she had lost over 15 pounds, and she is
sustaining hair loss. It took approximately six weeks following arrival to the MDC for Ms.
Maxwell to be permitted personal calls on par with other inmates; previously she was given two
calls per month unless authorized by the warden. While generally permitted to be out of her
isolation cell and confined to the day room from 7:00 am to 8:00 pm with one hour of recreation
time, general population inmates are permitted to be out of their cells until 9:30 pm and given
more extensive recreation time. While flashlight checks may be performed during regular
rounds, Ms. Maxwell is subject to such checks every 15 minutes. Further, because Ms. Maxwell
is kept in isolation, she in not permitted to participate in activities accorded inmates in general
population, such as programming (educational, leisure and wellness), movies, religious services,
job assignment.
Touting that Ms. Maxwell is not in contact with “a number of inmates who have tested
positive for COVID-19,” the MDC’s letter totally ignores that she was in contact with a member
of her revolving security team who tested positive, necessitating that Ms. Maxwell be
quarantined for 14 days. This further diminished her ability to prepare her defense and resulted in
cancelled legal visits. While the letter accurately states that one video teleconference (VTC) was
DOJ-OGR-00001866