LAW OFFICES OF BOBBI C.STERNHEIM

LAW OFFICES OF BOBBI C.STERNHEIM 33 West 19th Street - 4th Floor New York, New York 10011 February 16, 2021 Honorable Alison J. Nathan United States District Court United States Courthouse 40 Foley Square New York, NY 10007 Re: United States v. Ghislaine Maxwell 20 Cr. 330 (MN) Dear Judge Nathan: The government's recent letter regarding MDC conditions (Dkt.158) essentially repeats the same points it made in defense of the MDC's request that the Court vacate its order directing the MDC to permit Ms. Maxwell to use a laptop on weekends and holidays. We appreciate the Court's concern regarding Ms. Maxwell's opportunity to review discovery and the extent to which she is required to undergo searches. The government's letter, however, does not include the concerns defense counsel has reported to MDC Legal during the past couple of months. In addition, the letter incorrectly states that legal calls are available on Saturdays. Such requests by counsel have been denied. By i