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Case 1:20-cr-00330-PAE Document 408 _ Filed 11/03/21 Page6éof7 LAW OFFICES OF BOBBI C. STERNHEIA\ approximately 5:30 a.m. and was placed in a cold cellblock without the opportunity to retain and review her legal file. Nor was she provided any soap or any disinfectant to wash her hands, in disregard of CDC pandemic protocols. When she caught a few minutes of sleep in the holding cell, a marshal jabbed her in the leg to get her attention.® She is already sleep deprived. Should she be subjected to these conditions throughout the trial, it is highly likely that she will not have the stamina to assist in her defense and endure the physical demands of a five-day per week, multi-week court proceedings under the current onerous conditions of her detention. The Court and the defense are now in possession of Jencks Act and Giglio material regarding the four accusers which contradict the purported “strength” of the government’s case. Contrary to the government’s claim — which the Court relied on to repeatedly deny Ms. Maxwell’s robust bail applications — there is no independent corroboration for the accusers’ respective allegations of abuse. Their respective statements do not corroborate one another and further demonstrate contamination and collusion from various sources. These disclosures substantially undermine the strength of the government’s case and underscore the fact that Ms. Maxwell should not be detained. ° The male marshal assigned to Ms. Maxwell’s detail on Monday was inappropriately rough with and threatening to her. After returning Ms. Maxwell to the 4" floor cell block at 500 Pearl following the court appearance at 40 Foley Square, a round trip that required Ms. Maxwell to navigate stairs while in leg shackles, the marshal was verbally threatening. His brusque manner was evident in the courtroom. When alone with Ms. Maxwell, he stated, in substance: “You think you are special. You are not special. Remember you are in custody and the judge doesn’t care about you”’ Ms. Maxwell was placed in a holding cell where she remained, unaware whether she would be brought to the U.S. Attorney’s Office on the 5" Floor of 500 Pearl Street for a scheduled evidence review of which the marshal was aware. Ms. Maxwell does not need to be reminded that she is in custody and that she is being treated worse than most other pretrial detainees. It is especially concerning when a pretrial detainee is treated more abusively in court than in the MDC. The marshal’s vitriol runs counter to the presumption of innocence and reflects poorly on the district’s Marshal Service. I made a complaint to the U.S. Marshal and have requested that this particular marshal not be assigned to Ms. Maxwell’s detail in the future. Marshal Ralph Sozio promptly responded and informed me that the issue is under investigation. DOJ-OGR-00006061