Case 1:20-cr-00330-AJN Document 258 Filed 04/29/21 Page 1 of 1
LAW OFFICES OF BOBBI C. STERNHEIA
212-243-1100 © Main 33 West 19th Street - 4th Floor
917-306-6666 ® Cell New York, New York 10011
888-587-4737 ° Fax
[email protected]
April 29, 2021
Honorable Alison J. Nathan
United States District Judge
United States Courthouse
40 Foley Square
New York, NY 10007
Re: United States v. Ghislaine Maxwell
S2 20 Cr. 330 (AJN)
Dear Judge Nathan:
MDC Legal persists in falsely accusing Ms. Maxwell’s counsel of violating MDC
Brooklyn’s legal visit procedures. This allegation is reckless, false, and defamatory. At no time
did counsel provide documents to Ms. Maxwell for her retention that did not originate from Ms.
Maxwell. The April 29" letter from MDC Legal states that "supervisory staff...reviewed video
surveillance footage" but notably does not state the contents of that video surveillance. The fact
that MDC Legal does not claim to have reviewed the video or report the contents of the video
footage speaks volumes.
Further and contrary to MDC’s letter, MDC staff did in fact “seize and retain” Ms.
Maxwell’s confidential legal documents after the legal visit on April 24. While most of those
documents were returned to Ms. Maxwell, other documents, which the MDC concedes were
“confiscated,” were not returned to her but rather given to her counsel the next day. As
previously stated, documents returned to Ms. Maxwell’s counsel was “legal mail” which had
been sent to Ms. Maxwell some time prior to April 24. Counsel did not bring those documents
into the facility.
The MDC admits, and flouts the fact, that guards read Ms. Maxwell’s confidential
materials. This is no small matter. Ms. Maxwell is working tirelessly to review and discuss with
her attorneys literally millions of pages of documents. Deterioration of her confidential
communications with her attorneys does not produce a fair and just trial.
We press our request that the Court direct the MDC to provide Ms. Maxwell’s counsel
with a copy of the video recording.
Very truly yours,
Bobki C. Stern heim
BOBBI C. STERNHEIM
cc: All counsel of record
MDC Legal
DOJ-OGR-00004060