Case 1:20-cr-00330-AJN Document 429 Filed 11/09/21 Page 1 of 2
LAW OFFICES OF BOBBI C. STERNHEIA\
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November 9, 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:
The government’s opposition to releasing Ghislaine Maxwell from pretrial detention
(Dkt. 423) is a long-winded regurgitation of prior writings and rulings and underscores its
determination to ignore the presumption of innocence and punish Ms. Maxwell pretrial for her
association with Jeffrey Epstein. The indictment against her federalizes a New York State B
misdemeanor which carries a maximum penalty of 90 days. Ms. Maxwell, who awaits trial, has
served that five times over. Ms. Maxwell is not, and has never been, a flight risk. At every
opportunity, Ms. Maxwell has vigorously asserted her innocence and her eagerness to face these
unsubstantiated charges in court. She should be allowed to do so outside of the confines of the
MDC, where her conditions of confinement significantly impede her ability to prepare for trial,
negatively impact her health, and compromise her stamina to endure the rigors of trial.
The Court now has the 3500 material and Giglio material which seriously undermine the
strength of the government’s case and underscore the lack of corroboration, facts which the
government cannot and does not even attempt to refute. Rather, the government urges the Court
to rely on prior rulings that were based on government conjecture that is not substantiated by
recent disclosures. The Court and defense now have the witness statements, and they seriously
call into question prior rulings based on the purported strength of the government’s case.
DOJ-OGR- 00006328