Case 1:20-cr-00330-PAE Document 346 Filed 10/14/21 Page1lof3
LAW OFFICES OF BOBBI C. STERNHEIA\
212-243-1100 * Main 225 Broadway, Suite 715
917-912-9698 ® Cell New York, NY 10007
888-587-4737 ° Fax
[email protected]
October 14, 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:
I respectfully request that the Court issue an order directing the MDC to provide to Ms. Maxwell
all legal mail, including mailings sent or hand-delivered by counsel and the government, within one day
of receipt by the MDC. A hard drive containing Court-ordered disclosures (3500 material, non-testifying
witness materials, and the Government’s proffered exhibits) was sent via FedEx by the Government on
October 11 and received by the MDC on October 12. The hard drive was not provided to Ms. Maxwell
until late morning today, October 14.
This is but the latest episode in the persistent practice by MDC of delaying delivery to Ms.
Maxwell of critical legal materials sent to the MDC via FedEx and/or the U.S. Postal Service or hand-
delivered and deposited by counsel in the legal mailbox. Legal mail deposited in the MDC legal mailbox
on October 2 was not discovered by the MDC until October 7, after staff insinuated that Ms. Maxwell’s
counsel had not deposited it in the mailbox. When finally discovered, a questionable bar code sticker
was attached to the envelope that was not affixed by counsel or familiar to MDC staff, suggesting that it
had been tampered with. This was brought to the attention of the Warden. The Unit Manager contacted
counsel regarding this irregularity and personally returned the legal mail to counsel on October 9. These
ongoing delays have interfered with Ms. Maxwell’s ability to prepare for trial and to confer with
DOJ-OGR-00005229