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Case 1:20-cr-00330-AJN Document 159 Filed 02/16/21 Page 1 of 3

LAW OFFICES OF BOBBI C. STERNHEIM

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bc@sternheimlaw.com

February 16, 2021

Honorable Alison J. Nathan
United States District Court
United States Courthouse
40 Foley Square
New York, NY 10007

Re: United States v. Ghislaine Maxwell
20 Cr. 330 (AJN)

Dear Judge Nathan:

The government’s recent letter regarding MDC conditions (Dkt.158) essentially repeats
the same points it made in defense of the MDC’s request that the Court vacate its order directing
the MDC to permit Ms. Maxwell to use a laptop on weekends and holidays. We appreciate the
Court’s concern regarding Ms. Maxwell’s opportunity to review discovery and the extent to
which she is required to undergo searches. The government’s letter, however, does not include
the concerns defense counsel has reported to MDC Legal during the past couple of months. In
addition, the letter incorrectly states that legal calls are available on Saturdays. Such requests by
counsel have been denied.

By ignoring the myriad other issues reported by counsel, the government’s letter
misrepresents Ms. Maxwell’s conditions of confinement. Ms. Maxwell does not have access to
daily discovery review for the entirety of the 13 hours. The vagaries and delays of moving her
the 50 feet or so from the isolation cell to the day room are a large part of the challenge.

The number of searches is also not correct. Ms. Maxwell is searched on every move,
including to the empty concrete space, adjacent to the day room, used for recreation. Currently,
she is subject to a minimum of four pat down searches a day if she goes to rec, and five pat down
searches on the day of her weekly body scan. Since July 6th, Ms. Maxwell has been physically
searched approximately 1400 times, including pat down searches, metal wand searches, mouth,
hair and ear searches (posing additional health risks during COVID), and upwards of 60 body
scans. In addition, there have been hundreds of physical searches of her isolation cell, locker,
legal papers, and personal effects. No contraband has ever been found.

We take issue with MDC’s assessment that “the searches are all necessary for the safety
of the institution and the defendant.” Ms. Maxwell is under 24-hour surveillance by two to six
guards and approximately 18 cameras, not including the hand-held camera, focused on her
throughout the areas in which she is moved and confined. Ms. Maxwell poses no danger to
anyone. Her restrictive conditions, searches, and constant surveillance correlate directly to BOP
negligence resulting in the death of Jeffrey Epstein.

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