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Case 1:20-cr-00330-AJN Document 292 Filed 04/07/21 Page 1 of 5
LAW OFFICES OF BOBBI C. STERNHEIM
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April 7, 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 letter of April 6th is yet another regurgitation of its previous letters regarding Ms. Maxwell’s conditions of confinement. No matter how often the government tries to present Ms. Maxwell’s detention as superior to other inmates, it continues to miss the mark. We stand by our previous responses and reiterate that Ms. Maxwell’s detention is unwarranted and overly restrictive. It is tantamount to “pay-it-forward” punishment served pretrial.

The government’s letter provides the opportunity to flush out the persistent unsanitary conditions at the MDC, which long predate Ms. Maxwell’s detention. This past weekend there was a pervasive stench of sewage in Ms. Maxwell’s unit necessitating guards to flush pipes by pouring water down open drains in an effort to trap and disperse gaseous emissions. As guards explained to Ms. Maxwell, there are three drains in the day area, and when the plumbing system goes unused, gases escape from the drains and cause the stench. At times the stench in Ms. Maxwell’s isolation cell has been overwhelming due to overflowing of toilets in the cellblock above. Due to lack of privacy, Ms. Maxwell refrains from using the toilet in the isolation cell and, as directed by the guards, she flushes frequently to avoid plumbing problems. At times, the stench is apparent upon entering the visiting area. Of the many defense counsel who visit

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