Document EFTA 02833289¶
212-243-1100 • Main 225 Broadway, Site 715 917-912-9698 • Cell New York, NY 10007 888.587-4737 • Fax bcstemheim@mac.com¶
October 29, 2021¶
Honorable Alison J. Nathan United States District Judge United States Courthouse 40 Foley Square New York, NY 10007¶
Re: United Stales v. Ghislaine Maxwell S2 20 Cr. 330 (AJN)
¶
Dear Judge Nathan:¶
Ghislaine Maxwell requests that the Court issue an order requiring delivery of her legal mail within one business day of receipt by the post office. (See Dkt. 350.) The problems encountered by legal mail delays continue. I have attempted to address this with MDC Legal via email (but at times receive no response) and have conferred with government counsel. Only after two emails were sent today, the latter informing MDC Legal that failure to respond would result in the filing of an order to show cause, did I receive a response: “There was mail picked up today,” but no indication when Ms. Maxwell will receive the mail.¶
Legal mail sent by counsel through the United States Postal Service for “next day delivery” remains at the post office for pick up by the MDC. The mail is not picked up daily, as evidenced by tracking information (most recently obtained this morning) and often remains at the Post Office for days before retrieved by the MDC. (See Exhibit A.) The Court invited the defense to bring this issue to the Court’s attention if Ms. Maxwell does not receive mail within one business day of receipt. We are requesting that the Court direct the MDC to retrieve the mail within one business day of receipt by the post office so that legal mail sent “next day delivery” does not languish in the post office for days on end. The government suggests this may be due to resource issues at the MDC and reminds us that Ms. Maxwell’s mail is handled the same as that of other inmates. But unlike other inmates, Ms. Maxwell is¶
now a month away from trial and any delay receiving her legal mail impedes her ability to adequately prepare for trial.¶
Further, Ms. Maxwell is not receiving disclosures sent via Federal Express by the government in a timely manner. We have requested that within a month of commencement of trial, government disclosures be hand delivered to the MDC to alleviate delivery delays. The government has declined this request, again claiming resource issues. There is no assurance that Ms. Maxwell will receive legal mail — critical to trial preparation — in a timely manner. This is yet another example of how pretrial detention is encumbering Ms. Maxwell’s ability to prepare for trial and interfering with her ability to effectively communicate with counsel. This should undermine the Court’s confidence that Ms. Maxwell and her attorneys will be fully able to prepare for trial.¶
Very truly yours,¶
/s/¶
BOBBI C. STERNHEIM¶
cc: All counsel of record¶
EXHIBIT A¶
Tracking Number: EJG99•136 MOUS¶
SATURDAY¶
16¶
by October 19, 2021 at 6:51 am¶
6:00pm 0 BROOKLYN, NY 11232¶
Tracking Number: EJ699436435US¶
THURSDAY¶
14 OCTOJQER¶
2021 LO¶
6:00pm 0¶
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October 15, 2021 at 7:55 am BROOKLYN, NY 11232¶
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Tracking Number. EJ699436427US¶
Scheduled Delivery by Status¶
THURSDAY¶
28 OCTOBER¶
6:00pm¶
October 28, 2021 at 10:59 am BROOKLYN. NY 11232¶
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Tracking History ./¶
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Tracking Number. EJ699436413US¶
SATURDAY¶
OCTOBER 2021 (0¶
6:00pm 40¶
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October 12. 2021 at 9:07 am BROOKLYN, NY 11232¶
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