Case 1:20-cr-00330-PAE Document 300 _ Filed 06/15/21 Page1 of 32 LAW OFFICES OF BOBBI C. STERNHEIA 212-243-1100 © Main 33 West 19th Street - 4th Floor 917-306-6666 ° Cell New York, New York 10011 888-587-4737 ° Fax [email protected] June 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 S2 20 Cr. 330 (AJN) Dear Judge Nathan: This letter is submitted in response to the government’s letter of June 7, 2021, updating the Court concerning Ghislaine Maxwell’s conditions of detention. This letter, like the ones before it, contains second- and third-hand information and presents a one-sided review, giving the Court and the public the false impression that Ms. Maxwell is detained under favorable and privileged conditions. Each time, the defense feels compelled to respond to give the Court and the public a complete and accurate picture of Ms. Maxwell’s unacceptable conditions of confinement. This is not the purpose that these updates were designed to serve. Accordingly, the defense requests that any further updates be limited to changed circumstances. Counsel for Ms. Maxwell can personally attest to many problems that are not reported to the government, not conveyed to the Court, and not docketed for public review. The following is a sample of new and recurring problems: = Last week, raw sewage permeated Ms. Maxwell’s isolation cell, necessitating her removal to another cell. = Vermin droppings fell from air vents. = Guards now prevent Ms. Maxwell from removing legal documents from the videoconferencing room for review during the lunch hour. DOJ-OGR-00004744