. Andrew's Plaza New York, NY 10007 From: Sent: Wednesday, December 30, 2020 1:16 PM To: Cc: Subject: Ghislaine Maxwell 02879-509 > (USANYS) MDC Legal continues to provide inaccurate information. Contrary to the information provided to you as recited in your email of 12/29- "MDC legal counsel confi

From: To: Cc: ci )" Subject: Ghislaine Maxwell 02879-509 Date: Wed, 30 Dec 2020 18:15:39 +0000 MDC Legal continues to provide inaccurate information. Contrary to the information provided to you as recited in your email of 12/29- "MDC legal counsel confi

itor. She alerted MDC staff, and Case ManagerMvitnessed the activity. This is contrary to the Court's finding that "according to the Government and MDC Legal [Ms. Maxwell]'s difficulties communicating with counsel have been resolved" and contrary to "MDC's Legal assurances that [Ms. Maxwell]'s legal comm

submitted a letter on August 18 informing the Court about disruptions of attorney-client video teleconferences. Dkt. No. 319. After conferring with MDC Legal, the Government responded on August 23. Dkt. No. 326. According to the Government and MDC Legal, the Defendant's difficulties in communicating with

ember 30, 2020 2:52 PM To: (USANYS) (USANYS) Cc: (USANYS) Subject: RE: Maxwell Call > Thanks again for speaking with us earlier. I spoke with MDC legal, and they're fine with our proposal. They said they could submit a letter to the Court by Friday. We'll let you know how our conversation with defen

ember 30, 2020 2:52 PM To: (USANYS) (USANYS) Cc: (USANYS) Subject: RE: Maxwell Call > Thanks again for speaking with us earlier. I spoke with MDC legal, and they're fine with our proposal. They said they could submit a letter to the Court by Friday. We'll let you know how our conversation with defen

onitor. She alerted MDC staff, and Case Manageretnessed the activity. This is contrary to the Court's finding that "according to the Government and MDC Legal [Ms. Maxwell]'s difficulties communicating with counsel have been resolved" and contrary to "MDC's Legal assurances that [Ms. Maxwell]'s legal comm

and documents shown to her. That issue, which arose on June 14, 2021, was resolved between defense counsel and the MDC. However, on August 6, 2021, MDC Legal sent counsel an email stating that starting Monday (August 9th) we could no longer use defense counsel's WebEx platform for the VTCs, and instead ha

itions, counsel requested that the Warden provide a first-hand report to the Court and counsel. Following Court directive for a report from the MDC, MDC Legal submitted a letter that recited BOP policy but failed to address a number of concerns. 36 EFTA00065757 alerted the government on August 27, 2020

xtent to which she is required to undergo searches. The government's letter, however, does not include the concerns defense counsel has reported to MDC Legal during the past couple of months. In addition, the letter incorrectly states that legal calls are available on Saturdays. Such requests by counsel

itions, counsel requested that the Warden provide a first-hand report to the Court and counsel. Following Court directive for a report from the MDC, MDC Legal submitted a letter that recited BOP policy but failed to address a number of concerns. 36 EFTA00094330 alerted the government on August 27, 2020

and documents shown to her. That issue, which arose on June 14, 2021, was resolved between defense counsel and the MDC. However, on August 6, 2021, MDC Legal sent counsel an email stating that starting Monday (August 9th) we could no longer use defense counsel's WebEx platform for the VTCs, and instead ha

and documents shown to her. That issue, which arose on June 14, 2021, was resolved between defense counsel and the MDC. However, on August 6, 2021, MDC Legal sent counsel an email stating that starting Monday (August 9th) we could no longer use defense counsel's WebEx platform for the VTCs, and instead ha

itions, counsel requested that the Warden provide a first-hand report to the Court and counsel. Following Court directive for a report from the MDC, MDC Legal submitted a letter that recited BOP policy but failed to address a number of concerns. 36 EFTA00154553 alerted the government on August 27, 2020

itions, counsel requested that the Warden provide a first-hand report to the Court and counsel. Following Court directive for a report from the MDC, MDC Legal submitted a letter that recited BOP policy but failed to address a number of concerns. 36 EFTA00093257 Ccosel.211-ZMICERWlit Meutiskfit19302Frii

xtent to which she is required to undergo searches. The government's letter, however, does not include the concerns defense counsel has reported to MDC Legal during the past couple of months. In addition, the letter incorrectly states that legal calls are available on Saturdays. Such requests by counsel