Case 1:20-cr-00330-PAE Document 300 _ Filed 06/15/21 Page1 of 32
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
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[email protected]
June 15, 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:
This letter is submitted in response to the government’s letter of June 7, 2021, updating
the Court concerning Ghislaine Maxwell’s conditions of detention. This letter, like the ones
before it, contains second- and third-hand information and presents a one-sided review, giving
the Court and the public the false impression that Ms. Maxwell is detained under favorable and
privileged conditions. Each time, the defense feels compelled to respond to give the Court and
the public a complete and accurate picture of Ms. Maxwell’s unacceptable conditions of
confinement. This is not the purpose that these updates were designed to serve. Accordingly,
the defense requests that any further updates be limited to changed circumstances.
Counsel for Ms. Maxwell can personally attest to many problems that are not reported to
the government, not conveyed to the Court, and not docketed for public review. The following is
a sample of new and recurring problems:
= Last week, raw sewage permeated Ms. Maxwell’s isolation cell, necessitating her
removal to another cell.
= Vermin droppings fell from air vents.
= Guards now prevent Ms. Maxwell from removing legal documents from the
videoconferencing room for review during the lunch hour.
DOJ-OGR-00004744