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EFTA00030015.pdf
Defense attorney Bobbi Sternheim writes to Judge Alison Nathan objecting to a second superseding indictment filed against Ghislaine Maxwell just months before the scheduled July 2021 trial. The defense argues this expansion of charges (covering 1994-2004) constitutes tactical gamesmanship and abuse of power, potentially necessitating a delay in the trial. The letter also requests an in-person arraignment and a new bail hearing, citing issues with remote proceedings and referencing Maxwell's difficult detention conditions.
EFTA00028478.pdf
This document is an email chain from October 2020 between USANYS employees regarding discovery materials for the Ghislaine Maxwell case. Staff members are coordinating the location of physical and electronic files related to the Epstein investigation. A key detail emerges where a staff member notes the existence of emails with a US Marshal regarding Jeffrey Epstein's international travel and potential violations of the 'International Megan's Law.'
EFTA00025134.pdf
This document is an architectural floor plan and crime scene diagram of the 4th floor of Jeffrey Epstein's mansion at 9 East 71st Street, New York. Prepared by a Special Agent (SA), the diagram highlights specific zones (labeled M, X, Y, Z, N) containing guest bedrooms, bathrooms, a sitting room, and a specific room labeled 'Meditation room'. The document includes handwritten annotations regarding carpet types and room dimensions.
EFTA00021019.pdf
This document is a Notice of Motion filed on January 25, 2021, in the case of United States v. Ghislaine Maxwell (20 Cr. 330). The defense team, consisting of attorneys from three separate law firms, formally requests a severance and separate trial for Counts Five and Six of the Superseding Indictment. The filing includes the attorneys' contact information and signatures.
EFTA00013836.pdf
This document is an internal email chain dated November 10, 2009, discussing the storage and movement of physical files related to the Epstein case. The participants discuss moving boxes containing 'grand jury' materials, 'case files', and 'info' from the 9th floor back to a locked 'gj room' (grand jury room) on the 4th floor where transcripts are kept.
EFTA00011133.pdf
This document is a letter dated October 13, 2021, from U.S. Attorney Damian Williams to Ghislaine Maxwell's defense team. The Government asserts that Maxwell has waived her right to use an insanity or mental condition defense (Rule 12.2) because she failed to provide notice by the pretrial motion deadlines in early 2021. The letter demands that if the defense intends to use such evidence despite the waiver, they must provide notice by October 20, 2021.
EFTA00001100.pdf
An evidence photograph depicting an interior stairwell. The image shows a staircase with grey carpeting and a blue metal railing with a wooden handrail. Two fire extinguishers are mounted on the wall beneath a small black sign reading '4TH FLOOR'. A framed item hangs on the right wall. The Bates number/evidence tag 'EFTA00001100' is printed in the bottom right corner.
EFTA00000595.pdf
An evidence photograph showing a carpeted stairwell landing. The image captures a downward staircase with a blue railing and wooden handrail, a ceiling light fixture, and a wall-mounted sign reading '4TH FLOOR'. Below the sign are two fire extinguishers with yellow inspection tags. An evidence tag 'EFTA00000595' is visible in the bottom right corner.
EFTA00000221.pdf
A photograph showing an interior stairwell with grey carpeting and a blue railing. At the top of the stairs on the landing, two fire extinguishers are mounted on the wall beneath a black sign labeled '4TH FLOOR'. The image contains the evidence identifier EFTA00000221.
DOJ-OGR-00001866.jpg
This legal letter, sent by attorney Bobbi C. Sternheim on behalf of her client Ghislaine Maxwell to Judge Alison J. Nathan, formally complains about Maxwell's harsh and restrictive conditions at the Metropolitan Detention Center (MDC). The letter refutes a previous communication from MDC staff, detailing issues such as significant weight loss, isolation, constant surveillance, and a recent quarantine that hindered her defense preparation. Sternheim renews the request for the MDC Warden, Heriberto Tellez, to respond directly to the Court and justify these conditions.
DOJ-OGR-00001438.jpg
This legal letter, sent from attorney Bobbi C. Sternheim to Judge Alison J. Nathan, protests the detention conditions of her client, Ghislaine Maxwell, at the MDC. The letter argues that the 15-minute flashlight checks are disruptive and based on spurious justifications, such as 'enhanced security'. Sternheim refutes the government's claim that Maxwell possesses a contraband eye mask and provides evidence from an intake form showing Maxwell did not express safety concerns about being in the general population, contradicting the MDC's assertions.
DOJ-OGR-00002339.jpg
This document is a letter dated February 1, 2021, from attorney Bobbi C. Sternheim to Judge Alison J. Nathan regarding the case of United States v. Ghislaine Maxwell. Sternheim argues against the Metropolitan Detention Center's (MDC) objection to allowing Maxwell laptop access on weekends and holidays to review millions of pages of discovery documents. The letter asserts that the MDC's proposed alternative, a prison computer, is inadequate for the task and that the MDC has failed to provide a valid security or staffing reason for restricting laptop access, thereby impeding Maxwell's ability to prepare her defense.
DOJ-OGR-00001870.jpg
This is a letter dated October 29, 2020, from attorney Bobbi C. Sternheim to Warden Heriberto Tellez of the Metropolitan Detention Center (MDC). The attorney is writing on behalf of her client, Ghislaine Maxwell, to protest the 'extraordinarily restrictive conditions' of her detention, which are compared to solitary confinement and death row. The letter argues that these harsh measures are not a response to any threat Maxwell poses but are an overreaction by the Bureau of Prisons (BOP) to its failure to prevent the death of Jeffrey Epstein at a different facility.
DOJ-OGR-00001837.jpg
A legal letter from defense attorney Bobbi C. Sternheim to Judge Alison J. Nathan regarding the detention conditions of Ghislaine Maxwell. The letter disputes the government's portrayal of her confinement, alleging mistreatment including the deletion of legal emails, lack of hygiene supplies during quarantine, unauthorized photography of her cell, and lack of medical communication regarding COVID-19 exposure.
DOJ-OGR-00002729.jpg
A letter from defense attorney Bobbi C. Sternheim to Judge Alison J. Nathan disputing the government's characterization of Ghislaine Maxwell's confinement conditions at the MDC. The letter details excessive searches, lack of access to discovery materials, and argues that the strict surveillance is a reaction to BOP negligence regarding Jeffrey Epstein.
DOJ-OGR-00002884.jpg
A legal letter dated March 31, 2021, from attorney Bobbi C. Sternheim to Judge Alison J. Nathan regarding the case United States v. Ghislaine Maxwell. The defense objects to a second superseding indictment filed by the government, characterizing it as 'tactical gamesmanship' that expands the conspiracy timeline (1994-2004) and adds charges based on old evidence against Jeffrey Epstein. Sternheim expresses concern over Maxwell's health and ability to stand trial, notes the government's refusal to provide accuser names, and requests a conference to discuss moving the July 12th trial date.
DOJ-OGR-00020316.jpg
A legal letter from attorney Bobbi C. Sternheim to Judge Alison J. Nathan regarding United States v. Ghislaine Maxwell. The letter refutes the government's claims about Maxwell's detention conditions, arguing they are overly restrictive and punitive. It details unsanitary conditions at the MDC, specifically a recent incident involving a severe sewage stench, overflowing toilets from the floor above, and plumbing issues in Maxwell's isolation cell.
DOJ-OGR-00002907.jpg
This is a letter dated April 7, 2021, from attorney Bobbi C. Sternheim to Judge Alison J. Nathan regarding the case of United States v. Ghislaine Maxwell. The letter strongly objects to the conditions of Ms. Maxwell's pretrial detention at the MDC, describing them as a form of "'pay-it-forward' punishment." It details a recent incident involving a pervasive sewage stench in her unit and argues that the government's portrayal of her confinement as superior is inaccurate and misses the point of her overly restrictive and unwarranted detention.
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