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CaGede20 eb QO3304AUNt Deu tiwent/2722 1Fits@ BSH07 /2agPlagef Lof 3 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 May 7, 2020 Honorable Alison J. Nathan United States District Court United States Courthouse 40 Foley Square New York, NY 10007 Re: United States v. Ghislaine Maxwell S2 20 Cr. 330 (AJN) Dear Judge Nathan: Once again, the government reports second- and third-hand information from the MDC, the reliability of which becomes increasingly questionable. In its May 5" letter regarding the MDC’s flashlight security checks of Ms. Maxwell (Dkt. 270), the government contradicts a previous report that Ms. Maxwell “has an eye mask.” This allegation, immediately refuted by her counsel, was a focus of the Second Circuit’s questioning during oral argument of Ms. Maxwell’s bail appeal. Now, the government reports that the MDC cannot provide an eye mask to Ms. Maxwell and that an eye mask is considered contraband. This alone is a basis for the Court to question the veracity of representations made by the MDC. To justify the 15-minute flashlight surveillance that is causing Ms. Maxwell’s disruptive sleep and sleep deprivation, the MDC claims that Ms. Maxwell is on “‘an enhanced security schedule.” The reasons given to support the need for “heightened safety and security concerns” with respect to Ms. Maxwell are spurious. They single out Ms. Maxwell to the detriment of other pretrial detainees who face even more serious charges and potential stress (7.e., defendants charged with murder and terrorism offenses subjected to life sentences without possibility of release and the death penalty) and who are incarcerated in cells by themselves. The MDC attempts to shift the focus of its conduct by claiming that it is responsive to Ms. Maxwell’s “expressed concern for her safety if she were housed in general population.” The MDC should fact check its records before making bold assertions. The Intake Screening Form completed by Ms. Maxwell upon entry to the MDC on July 6, 2020 posed the following question: “Do you know of any reason why you should not be placed in general population?” Ms. Maxwell responded “No.” It is the MDC, not the inmate, who makes the determination regarding general population or degree of segregation. The Intake Screening DOJ-OGR-00020356