EFTA00015911.pdf

From: BOBBI C STERNHEIM [Redacted]
To: [Redacted]
Cc: Christian Everdell [Redacted], "Mark S. Cohen"
[Redacted]
Subject: Ghislaine Maxwell 02879-509
Date: Tue, 29 Dec 2020 01:41:41 +0000

Good evening, [Redacted]
We hope you and your family had a joyful holiday.
In response to your 12/14 email, we are requesting that Ms. Maxwell be permitted to use the laptop,
in lieu of the MDC computer,, during the typical length of time other inmates are permitted out of
their cells (our understanding is 6 am - 9:30 pm daily, extended to 10:30 pm on weekends.)
The voluminous discovery is easier to access and review on the laptop. The MDC computer turns
off every two hours and is not capable of opening all documents, and volume of discovery may be too
taxing for the operating system.
We also want to bring to your attention some of the ongoing issues concerning Ms. Maxwell’s
conditions and restrictions.
The constant rotation of security staff results in inconsistency of rules and restrictions, the current
shift being unnecessarily restrictive, punitive, and threatening.
Ms. Maxwell is ordered to remain in specific locations within her isolation cell
to accommodate capture on the handheld camera, restricting her use of an already small
confinement area.
Her use of the laptop has been restricted.
She is invasively surveilled while showering.
Her cell is cold and precipitation accumulates on the concrete block walls.
Over the holiday weekend, a third blanket, used by Ms. Maxwell to keep herself warm, was removed
leaving her cold; and she now has the onset of a cold.
The blanket was returned the next day, after complaint was made by counsel.
The open-mouth, wanding, pat-down, and in-and-behind ear searches continue,
with more frequently than other inmates are searched.
Her cell and legal papers are searched multiple times a day, a disruption to the organization of her
legal work and an invasion into her privileged work product.
She has not received daily newspapers for almost 3 weeks, and has not received certified mail
(return receipts indicating delivery to MDC on 12/17) and non-certified mail for more than a week.
We will keep you apprised of our concerns.
Your assistance is appreciated.
Best-
Bobbi

BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
[Redacted]
[Redacted]

EFTA00015911

[Redacted]
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EFTA00015912