DOJ-OGR-00004034.jpg

Casas: 2Q20rOCRRSP AON Ducunrent2468 AréetOeH25/221 Patayé 6fdt 9 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 April 26, 2021 VIA EMAIL AND U.S. MAIL Sophia Papapetru, Esq. Legal Counsel Metropolitan Detention Center 80 29% Street Brooklyn, NY 11232 spapapetru@bop.gov NOTICE AND DEMAND TO PRESERVE ITEMS OF EVIDENCE Re: Ghislaine Maxwell 02879-509 Dear Ms. Papapetru: As counsel for Ghislaine Maxwell, 02879-054, I am notifying you, as legal counsel for the Metropolitan Detention Center, of the MDC’s obligation to preserve documents and evidence related to (i) allegations made against Ms. Maxwell and her counsel regarding legal paperwork allegedly passed to Ms. Maxwell during an attorney-client conference on April 24, 2021 and (11) the confiscation and review of Ms. Maxwell’s documents by MDC staff. As stated in my April 24" email, material relevant to this dispute includes, but is not limited to: ° Any images, data files, or video recordings of the legal conference as captured on the hand-held camera focused on Ms. Maxwell and counsel during the entirety of the legal conference. ° Any images, data files, or video recordings of the legal conference as captured on surveillance cameras focused on Ms. Maxwell and counsel during the entirety of the legal conference. ° The full names of all guards, including the lieutenant, present in the visiting room during the legal conference. ° Any written or recorded communications, whether stored in electronic, digital or paper format, obtained in connection with the incident identified above. ° A list of all documents claimed to be in Ms. Maxwell’s possession upon entering the visiting room. This request includes copies of any such documents or notes regarding same. EXHIBIT C DOJ-OGR- 00004034