From: To: BOBBI C STERNHEIM Cc: Christian Everdell Subject: RE: Ghislaine Maxwell 02879-509 Date: Tue, 29 Dec 2020 17:49:42 +0000 "Mark S. Cohen" Bobbi, I just spoke with MDC legal counsel. Below are the responses to your concerns: • MDC legal confirmed that since the beginning of the pandemic, MDC inmates in general population have been permitted out of their cells for no more than 3 hours per day. For approximately the past month, MDC inmates in general population have been permitted out of their cells for no more than 30 minutes per day due to a lockdown at the institution. When that lockdown is lifted, inmates will still be permitted out of their cells no more than 3 hours per day while the pandemic persists. Accordingly, Ms. Maxwell has far more hours out of her cell than any other inmate in the MDC at this time. The MDC will not further expand that time. As I previously noted, if general population inmates eventually end up receiving more than 13 hours per day out of their cells, I will ask that Ms. Maxwell receive the same amount of time. • I have again asked MDC legal counsel if Ms. Maxwell may use the laptop on weekends. MDC legal counsel indicated they would pass that request up their chain and would circle back to me with a response. • MDC legal counsel confirmed that no staff member has ever directed Ms. Maxwell to remain in a particular location within her isolation cell. They confirmed that staff understand that no such directions should be given. • MDC legal counsel confirmed that Ms. Maxwell has continued to have access to the laptop 13 hours per day every weekday. That access has been documented, and MDC legal counsel is not aware of any restrictions on Ms. Maxwell's use of the laptop during those times. • MDC legal counsel confirmed that staff absolutely cannot see Ms. Maxwell when she showers and do not record her when she showers. They indicated that Ms. Maxwell has two shower curtains that cover her when she showers such