DOJ-OGR-00001870.jpg

Case 1:20-cr-00330-AJN Document 91 Filed 12/07/20 Page 5 of 10 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 bc@sternheimlaw.com October 29, 2020 Via Email/Regular Mail Warden Heriberto Tellez Metropolitan Detention Center Office of the Warden 80 29" Street Brooklyn, New York 11232 Re: Ghislaine Maxwell 02879-509 Dear Warden Tellez: As counsel for Ghislaine Maxwell, we again seek your urgent attention concerning issues related to conditions of her detention at the MDC.! Our immediate goal is to rectify these problems and improve the extraordinarily restrictive conditions under which Ms. Maxwell is presently confined within your facility. On July 14, 2020, the Honorable Alison J. Nathan entered an order of detention remanding Ghislaine Maxwell to the custody of the Bureau of Prisons. She has been detained since her arrest on July 2, 2020 and has been incarcerated at MDC under conditions that rival those at USP Florence ADMAX. An exemplary inmate who poses no threat to her personal safety or danger to anyone, she has spent the entirety of her detention in de facto solitary confinement, tantamount to imprisonment as a defendant convicted of capital murder and incarcerated on death row. The conditions of her detention are utterly inappropriate, especially so for a non-violent defendant with no prior criminal history facing non-violent charges a quarter- century old. Without a doubt, the BOP has imposed extraordinarily onerous conditions of constraint on Ms. Maxwell to avoid the catastrophic consequences of negligence occurring at the Metropolitan Correctional Center (MCC- Manhattan) which resulted in the death of Jeffrey Epstein. The Attorney General of the United States has said as much. The BOP has admitted that the sanctions are not in response to a specific threat that Ms. Maxwell has shown; rather they are in response to the high-profile nature of the case and the acknowledged failure by the BOP to keep Epstein — an actual threat to himself — alive. Ms. Maxwell is bearing the brunt of incompetence on MCC’s watch. As ABC News reported: ' Previous letters were sent to you on August 28, 2020 and September 9, 2020. DOJ-OGR-00001870