Case 1:20-cr-00330-PAE Document 326 Filed 08/23/21 Page 1 of 3 U.S. Department of Justice United States Attorney Southern District of New York The Silvio Mono Building One Saint Andrew's Plaza New York. New York 10007 August 23, 2021 BY ECF The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully submits this letter pursuant to the Court's Order dated August 19, 2021 (Dkt. No. 321) directing the Government to confer with legal counsel at the Metropolitan Detention Center ("MDC") and to file a response to the defense's letter dated August 18, 2021 (Dkt. No. 319). The Government has conferred with legal counsel at the MDC, and this letter is based on information provided to the Government during that conferral. As the Court is aware, over the past several months, the defendant has been provided with five hours of video-teleconference ("VTC") calls with her attorneys every weekday. MDC legal counsel has assured the Government that no MDC staff members have interfered with, recorded, or otherwise listened to the defendant's VTC meetings with counsel. Previously, the defendant's VTC sessions with counsel were conducted over a WebEx connection generated by defense counsel. Recently, however, the MDC determined that the use of a VTC connection generated outside of the Bureau of Prisons ("BOP") system posed a security threat and could more easily be accessed by third parties than a VTC connection generated by the BOP itself. In order to address that security concern, the MDC provided its own BOP-generated VTC virtual room for the defendant and her attorneys to use. EFTA02832849