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Case 1:20-cr-00330-PAE Document 300 Filed 06/15/21 Page 2 of 32
LAW OFFICES OF BOBBI C. STERNHEIM

- On Sunday, guards initially refused to allow Ms. Maxwell to bring a notebook to a scheduled in-person legal conference, disbelieving her assertion that it contained legal material. A guard reviewed the contents of the notebook, reading pages containing confidential and privileged work product, before permitting Ms. Maxwell to bring the notebook to the legal visit.

- Contrary to previous legal conferences, neither counsel nor Ms. Maxwell were permitted to have any water in the individual conference room during Sunday’s four-hour legal conference.

- Three to six guards watched Ms. Maxwell and counsel for the entirety of the conference.

- Neither counsel nor Ms. Maxwell were permitted to use the most rudimentary of earbuds to listen to audio files on counsel’s laptop, requiring the volume to be raised to maximum level. Ms. Maxwell cannot have privileged communications with her counsel and adequately prepare for trial if the prison guards can hear what she is reviewing and discussing with counsel.

- The prison guards ordered counsel to reposition her portfolio, which was being used to shield glare from the plexiglass divider separating counsel from Ms. Maxwell to permit counsel to have a clearer view of the laptop, because the portfolio was restricting the guards’ view of counsel.

- At one point, a prison guard interrogated counsel about what she was doing with her hands. (Counsel was blotting a bleeding finger with note paper.)

- At the conclusion of Sunday’s legal visit, counsel requested that the guards inventory Ms. Maxwell’s documents in the presence of counsel to avoid the problem that ensued following the April 24th visit when counsel was falsely accused of improperly leaving documents with Ms. Maxwell.

- Yesterday, the monitor which has been used for video conferencing for months was repositioned to a distance further away from Ms. Maxwell impacting her ability to review screen-shared documents with counsel. The request was immediately denied.

- Today’s videoconferencing was reduced by 90 minutes while changes were made to MDC equipment. These changes have disrupted videoconferencing, which had been working well, and now severely impact attorney-client communication and the ability to prepare the case for trial. On counsel's end, the audio is impacted by a whirling, whistling sound - like water going down a drain. The video is completely blurred, causing eye strain, and compromising the sharing of documents, which are too hazy to decipher. On the MDC end, the audio is loud and echoes, making it difficult to understand and audible to staff, compromising attorney-client confidentiality. The monitor- now enclosed in a box with a plastic cover - is now positioned some three to four feet away from Ms. Maxwell. This distance impacts Ms. Maxwell’s ability to view screen-shared documents and requires her to contort her body - back and neck - and risk further injury while attempting to see shared legal documents.

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