Case 1:20-cr-00330-PAE Document 381 Filed 10/29/21 Page1lof5
LAW OFFICES OF BOBBI C. STERNHEIA\
212-243-1100 * Main 225 Broadway, Suite 715
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[email protected]
October 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:
Ghislaine Maxwell requests that the Court issue an order requiring delivery of her legal mail
within one business day of receipt by the post office. (See Dkt. 350.) The problems encountered by
legal mail delays continue. I have attempted to address this with MDC Legal via email (but at times
receive no response) and have conferred with government counsel. Only after two emails were sent
today, the latter informing MDC Legal that failure to respond would result in the filing of an order to
show cause, did I receive a response: “There was mail picked up today,” but no indication when Ms.
Maxwell will receive the mail.
Legal mail sent by counsel through the United States Postal Service for “next day delivery”
remains at the post office for pick up by the MDC. The mail is not picked up daily, as evidenced by
tracking information (most recently obtained this morning) and often remains at the Post Office for days
before retrieved by the MDC. (See Exhibit A.) The Court invited the defense to bring this issue to the
Court’s attention if Ms. Maxwell does not receive mail within one business day of receipt. We are
requesting that the Court direct the MDC to retrieve the mail within one business day of receipt by the
post office so that legal mail sent “next day delivery” does not languish in the post office for days on
end. The government suggests this may be due to resource issues at the MDC and reminds us that Ms.
Maxwell’s mail is handled the same as that of other inmates. But unlike other inmates, Ms. Maxwell is
DOJ-OGR-00005451