EFTA00024928.pdf

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Case 1:20-cr-00330-AJN Document 256 Filed 04/29/21 Page 1 of
LAW OFFICES OF BOBBI C. STERNHEIM
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[email protected]
April 29, 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
S2 20 Cr. 330 (AJN)
Dear Judge Nathan:
USDC SONY
DOCUMENT
ELECTRONICALLY FILED
DOC 0:
DATE FILED: 4/29/21
During oral argument of Ghislaine Maxwell's bail appeal before the Circuit, Ms.
Maxwell's appellate counsel expressed concern that she was improperly deprived of sleep while
detained in the MDC, an issue that has been raised in filings before this Court. In its brief denial
of her appeal, the Circuit stated: "To the extent Appellant seeks relief specific to her sleeping
conditions, such request should be addressed to the District Court." See Exhibit A. We press our
concerns regarding disruption of Ms. Maxwell's sleep and the deleterious effect sleep
deprivation is having on her health, well-being, and ability to prepare for and withstand trial.
Ms. Maxwell continues to be disrupted throughout the night by guards shining a
flash/strobe light into her cell, claiming that her breathing must be checked. The myth that Ms.
Maxwell's conditions of confinement are related to her being a suicide risk was laid to rest
during the oral argument: There is nothing to support that contrived claim. In fact, Ms. Maxwell
is classified with the standard CC1-Mh designation: inmate with no significant mental health
care. (See Dkt. 159 at 3.)
Contrary to the report that Ms. Maxwell "wears an eye mask when she sleeps" (Dkt. 196
at 4), an item neither available for purchase through MDC commissary nor provided to her, she
resorts to using a sock or towel to cover her eyes in an awkward attempt to shield them from
disrupting illumination every 15 minutes. L…

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