EFTA00017821.pdf

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Source set: data-set-8

Extracted text

lase 1:20-cr-00330-AJN Document 76 Filed 11/24/20 Page 1 of 2
LAW OFFICES OF BOBBI C.STERNHEIM
212.243-1100 • Mole
917-306-6666 • Cell
888.587-4737 • Fax
Honorable Alison J. Nathan
United States District Judge
United States Courthouse
40 Foley Square
New York, NY 10007
Dear Judge Nathan:
33 West 19th Street - 4th Floor
New York, New York 10011
[email protected]
November 24, 2020
Re: United States v. Ghislaine Maxwell
20 Cr. 330 (AJN)
USDC SDNY
DOCUMENT
ELECTRONICALLY FILED
DOCO:
DATE FILED: 11/24/20
As counsel for Ghislaine Maxwell, I write in response to the government's letter, dated
November 23, 2020 (see Dkt 74), reporting Ms. Maxwell's conditions of detention and
confirming that she is currently in quarantine due to contact with a staff member, assigned to her
isolation pod, who tested positive for COVID-19.
The government recites a variety of allowances given Ms. Maxwell, including being
permitted out of her cell three times a week during quarantine for a maximum of 30 minutes, the
total time allotted for showering, making personal calls, and using the CorrLinks email system to
communicate with family and counsel. However, the letter presents an incomplete picture of
Ms. Maxwell's conditions of confinement.
The government fails to mention a variety of issues brought to the attention of the MDC,
including but not limited to the fact: that all email correspondence between Ms. Maxwell and
counsel was deleted in advance of the 180-day period, when deletion is expected to occur; that
after being administered two nasal swab tests, under threat of 21-day quarantine if she declined
to be tested, Ms. Maxwell was ordered to remove her COVID-protection mask for an in-mouth
inspection, further risking exposure to the virus; that Ms. Maxwell was initially quarantined
without soap or a toothbrush; that medical and psychology staff, who checked on Ms. Maxwell
daily pre-quarantine, have ceased doing so daily since quarantine and have ne…

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