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Case 1:20-cr-00330-PAE Document 408 _ Filed 11/03/21 Pagelof7
LAW OFFICES OF BOBBI C. STERNHEIA\
212-243-1100 * Main 225 Broadway, Suite 715
917-912-9698 ° Cell New York, NY 10007
888-587-4737 ° Fax besternhein@mac.com
November 3, 2021
Honorable Alison J. Nathan
United States District Judge
United States Courthouse
40 Foley Square
New York, NY 10007
Re: United States v. Ghislaine Maxwell
S2 20 Cr. 330 (AJN)
Dear Judge Nathan:
I write to once again ask the Court to release Ghislaine Maxwell prior to trial on the
conditions set forth in her previous bail applications. My weekly in-person legal visits with Ms.
Maxwell are conducted under the most humiliating circumstances that I have ever experienced in
many decades of federal criminal practice. As disturbing and invasive as they are for no
justifiable reason, I get to leave; Ms. Maxwell does not. The surveillance rivals scenes of Dr.
Hannibal Lecter’s incarceration as portrayed in the movie, “Silence of the Lambs,” despite the
absence of the cage and plastic face guard. Ms. Maxwell’s conditions of detention for the past
16 months continue to be reprehensible and utterly inappropriate for woman on the cusp of
turning 60 with no criminal record or history of violence. It is unwarranted, unrelenting, and
utterly inappropriate.
Ms. Maxwell has been subject to physical and emotional abuse by the correction officers,
poor and unsanitary living conditions, insufficient nutrition, difficulties reviewing the millions of
legal discovery documents in the case against her, and sleep deprivation. She has been
consistently housed in segregation from all other inmates, with rotating teams of multiple
corrections officers per daily shift which rotate on a bi-weekly basis. Many of the officers are
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| Filename | DOJ-OGR-00006056.jpg |
| File Size | 651.9 KB |
| OCR Confidence | 93.9% |
| Has Readable Text | Yes |
| Text Length | 1,784 characters |
| Indexed | 2026-02-03 17:06:51.385760 |