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Document 352

AI Analysis

Summary: Defense attorney Bobbi C. Sternheim writes to Judge Alison J. Nathan, criticizing the government's response to delayed delivery of Ghislaine Maxwell's legal mail and arguing that the situation is untenable and violates Maxwell's constitutional rights. Sternheim requests the court to reconsider Maxwell's detention.
Significance: This document highlights issues with the handling of Ghislaine Maxwell's legal mail and raises concerns about her constitutional rights, potentially impacting her trial preparation and detention status.
Key Topics: Delayed delivery of Ghislaine Maxwell's legal mail MDC's handling of legal mail and its impact on Maxwell's trial preparation Reconsideration of Maxwell's detention due to unmet constitutional rights
Key People:
  • Ghislaine Maxwell - Defendant in the case United States v. Ghislaine Maxwell
  • Bobbi C. Sternheim - Defense attorney for Ghislaine Maxwell
  • Alison J. Nathan - United States District Judge presiding over the case
Document Type
Letter
Date
10/15/21
Pages
2
Folder
IMAGES002

Full Text

Case 1:20-cr-00330-PAE Document 352 Filed 10/15/21 Page 1 of 2 LAW OFFICES OF BOBBI C. STERNHEIM 212-243-1100 · Main 917-912-9698 · Cell 888-587-4737 · Fax 225 Broadway, Suite 715 New York, NY 10007 bcsternheim@mac.com October 15, 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 20 Cr. 330 (AJN) Dear Judge Nathan: The Government's letter concerning delayed delivery of Ghislaine Maxwell's legal mail (Dkt. 350) merely parrots the MDC's standard excuses, adding a BOP version of "my dog ate my homework." The response is woefully inadequate and makes light of the MDC's encroachment on Ms. Maxwell's ability to prepare for trial and confer with counsel. It does not explain MDC's failure to respond to counsel's requests. It utterly fails to address the issue regarding the extremely late delivery of legal mail placed by counsel in the legal mailbox on October 2 but not discovered until October 7; nor the presence of a sticker with a bar code of the type issued by the U.S. Post Office and unfamiliar to the Warden and Unit Manager. If it is not too burdensome for the MDC to rotate in extra officers from BOP facilities nationwide to overmanage and monitor Ms. Maxwell's every move and every second she confers with counsel in the visiting room, the MDC should be able to deliver legal mail in a timely fashion. It is not surprising that the Government asserts that this case and the circumstances do not merit special expedited delivery. It dug its heels in when making it clear that it would not go out of its way to have the hard drive hand delivered to the MDC to ensure that Ms. Maxwell would receive it expeditiously, an accommodation it had previously made. DOJ-OGR-00005241 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 352 Filed 10/15/21 Page 2 of 2 LAW OFFICES OF BOBBI C. STERNHEIM It is time for the Government and the Court to seriously reconsider Ms. Maxwell's detention. This situation is untenable, unreasonable, and usurping Ms. Maxwell's constitutional rights. Very truly yours, /s/ BOBBI C. STERNHEIM cc: All counsel DOJ-OGR-00005242

Individual Pages

Page 1 - DOJ-OGR-00005241
Case 1:20-cr-00330-PAE Document 352 Filed 10/15/21 Page 1 of 2 LAW OFFICES OF BOBBI C. STERNHEIM 212-243-1100 · Main 917-912-9698 · Cell 888-587-4737 · Fax 225 Broadway, Suite 715 New York, NY 10007 bcsternheim@mac.com October 15, 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 20 Cr. 330 (AJN) Dear Judge Nathan: The Government's letter concerning delayed delivery of Ghislaine Maxwell's legal mail (Dkt. 350) merely parrots the MDC's standard excuses, adding a BOP version of "my dog ate my homework." The response is woefully inadequate and makes light of the MDC's encroachment on Ms. Maxwell's ability to prepare for trial and confer with counsel. It does not explain MDC's failure to respond to counsel's requests. It utterly fails to address the issue regarding the extremely late delivery of legal mail placed by counsel in the legal mailbox on October 2 but not discovered until October 7; nor the presence of a sticker with a bar code of the type issued by the U.S. Post Office and unfamiliar to the Warden and Unit Manager. If it is not too burdensome for the MDC to rotate in extra officers from BOP facilities nationwide to overmanage and monitor Ms. Maxwell's every move and every second she confers with counsel in the visiting room, the MDC should be able to deliver legal mail in a timely fashion. It is not surprising that the Government asserts that this case and the circumstances do not merit special expedited delivery. It dug its heels in when making it clear that it would not go out of its way to have the hard drive hand delivered to the MDC to ensure that Ms. Maxwell would receive it expeditiously, an accommodation it had previously made. DOJ-OGR-00005241
Page 2 of 2 - DOJ-OGR-00005242
Case 1:20-cr-00330-PAE Document 352 Filed 10/15/21 Page 2 of 2 LAW OFFICES OF BOBBI C. STERNHEIM It is time for the Government and the Court to seriously reconsider Ms. Maxwell's detention. This situation is untenable, unreasonable, and usurping Ms. Maxwell's constitutional rights. Very truly yours, /s/ BOBBI C. STERNHEIM cc: All counsel DOJ-OGR-00005242