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Case 1:20-cr-00330-PAE Document 346 Filed 10/14/21 Page3of3 LAW OFFICES OF BOBBI C. STERNHEIA\ to believe that Ms. Maxwell’s ability to defend and prepare for trial will continue to be severely compromised. The incompetence demonstrated by the MDC is concerning and gives counsel reason to believe that these problems will continue and that Ms. Maxwell will not receive vital trial materials with sufficient time to review them and confer with counsel. Counsel have wasted considerable time and effort to ensure that Ms. Maxwell can prepare for her upcoming trial under the most extraordinary and onerous conditions of pretrial release for a non-violent detainee with no criminal history, let alone a woman approaching the age of 60. The cost in time and dollars is wasteful and unacceptable. The consequence of inaction will be further erosion of Ms. Maxwell‘s constitutional rights and may result in delay of trial. Very truly yours, /s/ BOBBI C. STERNHEIM cc: All counsel DOJ-OGR-00005231