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NY 10007 Dear Judge Nathan: 33 West 19th Street - 4th Floor New York, New York 10011 [email protected] December 7, 2020 Re: United States v. Ghislaine Maxwell 20 Cr. 330 (AJN) As counsel for Ghislaine Maxwell, we write in response to the letter from MDC staff attorneys. (See Dkt. 8k) The letter fails to
it for the Court's consideration. (See Exhibit A.) We renew our request that Warden respond directly to the Court and counsel and explain why Ms. Maxwell must be detained under such harsh and restrictive conditions. Using the term "[lin her current assignment," the letter attempts to present a pictur
lmlow.com December 7, 2020 Re: United States v. Ghislaine Maxwell 20 Cr. 330 (AJN) As counsel for Ghislai
irectly to the Court and counsel and explain why Ms. Maxwell must be detained under such harsh and restrictiv
esulted in cancelled legal visits. While the letter accurately states that one video teleconference (VTC) was EFTA00040347 LAW OFFICES OF 1300131 C.STERNHEIM scheduled for August 17th, it fails to report that the VTC was unsuccessful because the audio connection failed; and, despite constant ongoing requ
ust 18, 2021 Honorable 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; I write to update the Court regarding MDC ongoing interference with attorney-client communication between
rence with attorney-client communication between Ghislaine Maxwell and her counsel. Since December 2019, video teleconferences ("VTCs") between Ms. Maxwell and her counsel have been conducted via defense counsel's WebEx platform. There were no problems with VTCs with the exception of when the MDC place
Square New York, NY 10007 Re: United States v. Ghislaine Maxwell S2 20 Cr. 330 (AJN) Dear Judge Nathan;
mber 2019, video teleconferences ("VTCs") between Ms. Maxwell and her counsel have been conducted via defense
tentionally) with Ms. Maxwell's privileged communication. That concern manifested itself on August 12ih when EFTA00040660 LAW OFFICES OF 13O13131 C.STERNHEIM third parties accessed the Zoom room used by Ms. Maxwell and counsel. This breach was reported to, and I believe witnessed by, MDC staff, including
OFFICES OF BOBBI C.STERNHEIM July 9, 2021 Honorable Alison J. Nathan United States District Judge United States Courthouse Re: United States v. Ghislaine Maxwell S2 20 Cr. 330 (AJN) Dear Judge Nathan: The below-signed counsel of record for Ghislaine Maxwell submit this letter in response to the Court's ord
han: The below-signed counsel of record for Ghislaine Maxwell submit this letter in response to the Court's order of July 2, 2021. (Dkt. 312). Ms. Maxwell's counsel of record have scrupulously complied with Local Criminal Rule 23.1 and assiduously refrained from any involvement with the media, despite
e United States Courthouse Re: United States v. Ghislaine Maxwell S2 20 Cr. 330 (AJN) Dear Judge Nathan:
o the Court's order of July 2, 2021. (Dkt. 312). Ms. Maxwell's counsel of record have scrupulously complied wi
itate to take appropriate action in the fact of violations of any relevant rules." (Dkt. 28) (July 23, 2020). 2 EFTA00087797 LAW OFFICES OF DOH' C.STERNHEIM representing any party or witness to the case. Their position on the applicability of Rule 23.1 apparently fluctuates depending on who is talking t
ust 18, 2021 Honorable 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; I write to update the Court regarding MDC ongoing interference with attorney-client communication between
rence with attorney-client communication between Ghislaine Maxwell and her counsel. Since December 2019, video teleconferences ("VTCs") between Ms. Maxwell and her counsel have been conducted via defense counsel's WebEx platform. There were no problems with VTCs with the exception of when the MDC place
Square New York, NY 10007 Re: United States v. Ghislaine Maxwell S2 20 Cr. 330 (AJN) Dear Judge Nathan;
mber 2019, video teleconferences ("VTCs") between Ms. Maxwell and her counsel have been conducted via defense
tentionally) with Ms. Maxwell's privileged communication. That concern manifested itself on August 12ih when EFTA00097874 LAW OFFICES OF 13O13131 C.STERNHEIM third parties accessed the Zoom room used by Ms. Maxwell and counsel. This breach was reported to, and I believe witnessed by, MDC staff, including
ust 18, 2021 Honorable 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; I write to update the Court regarding MDC ongoing interference with attorney-client communication between
rence with attorney-client communication between Ghislaine Maxwell and her counsel. Since December 2019, video teleconferences ("VTCs") between Ms. Maxwell and her counsel have been conducted via defense counsel's WebEx platform. There were no problems with VTCs with the exception of when the MDC place
Square New York, NY 10007 Re: United States v. Ghislaine Maxwell S2 20 Cr. 330 (AJN) Dear Judge Nathan;
mber 2019, video teleconferences ("VTCs") between Ms. Maxwell and her counsel have been conducted via defense
tentionally) with Ms. Maxwell's privileged communication. That concern manifested itself on August 12ih when EFTA00097871 LAW OFFICES OF 13O13131 C.STERNHEIM third parties accessed the Zoom room used by Ms. Maxwell and counsel. This breach was reported to, and I believe witnessed by, MDC staff, including
Entities connected to both Ghislaine Maxwell and C.STERNHEIM

Jeffrey Epstein
PERSONJeffrey Pagliuca
PERSONthe Southern District
LOCATIONLaura Menninger
PERSON
Alison J. Nathan
PERSONMDC Legal
ORGANIZATIONJ. Nathan
ORGANIZATIONMDC Zoom
ORGANIZATIONZoom, MDC Legal
ORGANIZATIONBOBBI C.STERNHEIM
PERSON