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Case 1:20-cr-00330-AJN Document 91 Filed 12/07/20 Page 6 of 10

LAW OFFICES OF BOBBI C. STERNHEIM

Attorney General William Barr told ABC News on Wednesday that he is keeping a close watch to make sure that Maxwell makes it to trial after Epstein died by suicide in a Manhattan jail while awaiting trial last year. Barr said he was "livid" Epstein died while in custody last August. The investigation into Epstein has continued even after his death. "I believe very strongly in that case," Barr told ABC News on Wednesday. "And I was very proud of the work done by the department, the Southern District [of New York], on that case. And as you will recall, after he committed suicide, I said that I was confident that we would continue to pursue this case vigorously and pursue anyone who's complicit in it. And so I'm very happy that we were able to get Ms. Maxwell." A source said the BOP is taking extra preventative measures to regain the public's trust and confidence as well as preserving the integrity of the Justice Department."²

What is clear is that the Government is “livid” over the death of Epstein and is seeking to repair its reputation by placing Ms. Maxwell under extraordinarily harsh conditions; not in any response to Ms. Maxwell’s requirements, but rather in response to the failed handling of a completely different defendant.

Ms. Maxwell has been an exemplary detainee who has never received a disciplinary demerit. The purpose of this letter is not simply to express complaint due to the institutional violations and denial of rights suffered by Ms. Maxwell in relation to her pretrial incarceration. Rather, it seeks to bring an unwarranted situation to your attention - conditions that are unduly cruel and punitive and circumstances that are deleteriously impacting our client’s ability to prepare her defense which, in turn, interferes with our ability to provide the legal representation to which she, and any other detainee, deserves.

We continue our ongoing attempt to resolve these matters without court intervention. We have voiced complaint through the MDC Legal Department, your office, the AUSAs in charge of this case, and the Federal Defenders of New York.³ Ms. Maxwell has attempted to resolve these matters by following the internal prison procedures, filing written complaints to her unit counselor (BP8), to the warden (BP9), and to the regional office (BP10), to seek remediation as set forth in the BOP manuals and inmate handbook. All to no avail.

Draconian Conditions of Pretrial Detention

Ms. Maxwell’s conditions of confinement are extraordinarily onerous - and unlike those of any other inmate at the MDC (or in BOP custody, to our knowledge). In fact, in the time that Ms. Maxwell has been at the MDC, she has met with five separate wardens and interim wardens, many who have remarked that they have never seen in their collective years of experience

² See, “Ghislaine Maxwell given paper clothes at correctional center to avoid suicide attempt: Sources Jeffrey Epstein, her associate, died by suicide in jail last August.” https://abcnews.go.com/US/ghislaine-maxwell-paper-clothes-correctional-center-avoid-suicide/story?id=71699000 (emphasis added).

³ The Federal Defenders of New York has been tasked with scheduling of attorney-client communication in connection with ongoing litigation against the MDC based on conditions of confinement during COVID pending in the Eastern District of New York before the Honorable Margo K. Brodie. See Federal Defenders of New York v. Federal Bureau of Prisons, et al., 19-CV-660 (MKB).

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