Maxwell counsel's dispute with MDC Brooklyn over confiscated legal documents, April 2021

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From: Sophia Papapetru¶

Subject: Legal Visit 04.24.21¶

Date: April 24, 2021 at 4:07 PM¶

SP¶

Cc: Nicole McFarland¶

Good afternoon Bobbi:¶

It had been brought to my attention by the staff of MDC Brooklyn that Ms. Maxwell received paperwork that was not in her possession upon entering the legal visiting area. As you are aware, the policies set forth for MDC Brooklyn legal visits do not allow for passing of any material during a legal visit. Due to our policy and procedures, the additional documents that were provided to Ms. Maxwell were confiscated. Those materials were put in an envelope and will be returned to you tomorrow upon your arrival to the institution. Please note, that you may put these documents in the legal mail box in the lobby of the east building.¶

Thank you for understanding.¶

Best, Sophia¶

EXHIBIT A¶

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Sophia-¶

Your accusation is inaccurate as is the information reported to you by your staff. Nothing in Ms. Maxwell ‘s legal papers was given to her by me or by Leah Saffian, Esq. Both Ms. Saffian and I dispute these allegations in the strongest terms.¶

Today, Ms. Saffian and I met with Ghislaine Maxwell for a scheduled legal visit- under the gaze of 5 guards and a portable camera recording audio and video.¶

After the legal visit concluded and Ms. Saffian and I left the visiting area, guards accused Ms. Maxwell of possessing documents obtained from counsel. The guards seized confidential documents from her, including documents she had previously received in legal mail delivered to the MDC and given to her by MDC staff. After seizing “highly confidential” documents (subject to a protective order that your staff is not authorized to review) and work product, the guards began reading the documents and have not returned them to Ms. Maxwell.¶

At no time did the guards, who were assiduously watching and filming the legal conference, bring any concern to my attention, so it is quite telling that you have been contacted when counsel are told that legal staff are unavailable during the weekend.¶

No documents were given to Ms.¶

Maxwell for her retention. Demand is hereby made for an immediate identification of the documents you claim were not in Ms.¶

Maxwell’s possession upon entering the legal visiting area in advance of the arrival of counsel, a list of all guards present during the visit, and a copy of the video recording.¶

Please immediately return the confiscated legal documents to Ms. Maxwell. They are her documents, not mine. The confiscation of these documents has deprived Ms. Maxwell of her time and seriously impaired her ability to review legal documents and prepare for an upcoming trial, adding to an already difficult situation.¶

This matter is being reported to the Court and legal action will be initiated.¶

Regarding tomorrow- I have recieved 15 different confirmations and cancellations regarding the scheduled visit for tomorrow, which will be attended by Ms. Saffian alone.¶

I am sorting through these emails to determine what time period is permitted for tomorrow’s visit. Bobbi¶

BOBBI C. STERNHEIM, ESQ.¶

Law Offices of Bobbi C. Sternheim¶

This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim¶

that may be confidential and/or privileged.¶

If you are not the intended recipient, you may not read, copy, distribute, or use this information.¶

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Thank you.¶

On Apr 24, 2021, at 4:07 PM, Sophia Papapetru < > wrote:¶

Good afternoon Bobbi:¶

It had been brought to my attention by the staff of MDC Brooklyn that Ms. Maxwell received paperwork that was not in her possession upon entering the legal visiting area. As you are aware, the policies set forth for MDC Brooklyn legal visits do not allow for passing of any material during a legal visit. Due to our policy and procedures, the additional documents that were provided to Ms. Maxwell were confiscated. Those materials were put in an envelope and will be returned to you tomorrow upon your arrival to¶

EXHIBIT B¶

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Case 1:20-cr-00330-AJN Document 248 Filed 04/26/21¶

the institution. Please note, that you may put these documents in the legal mail box in the lobby or the east building.¶

Thank you for understanding.¶

Best,¶

Sophia¶

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Case 1:20-cr-00330-AJN Document 248 Filed 04/26/21 Page 8 of 9¶

LAW OFFICES OF BOBBI C. STERNHEIM¶

212-243-1100 • Main¶

917-306-6666 • Cell¶

888-587-4737 • Fax¶

33 West 19th Street - 4th Floor¶

New York, New York 10011¶

bc@sternheimlaw.com¶

April 26, 2021¶

VIA EMAIL AND U.S. MAIL¶

Sophia Papapetru, Esq.¶

Legal Counsel¶

Metropolitan Detention Center¶

80 29th Street¶

Brooklyn, NY 11232¶

NOTICE AND DEMAND TO PRESERVE ITEMS OF EVIDENCE¶

Re: Ghislaine Maxwell 02879-509¶

Dear Ms. Papapetru:¶

As counsel for Ghislaine Maxwell, 02879-054, I am notifying you, as legal counsel for the Metropolitan Detention Center, of the MDC’s obligation to preserve documents and evidence related to (i) allegations made against Ms. Maxwell and her counsel regarding legal paperwork allegedly passed to Ms. Maxwell during an attorney-client conference on April 24, 2021 and (ii) the confiscation and review of Ms. Maxwell’s documents by MDC staff.¶

As stated in my April 24th email, material relevant to this dispute includes, but is not limited to:¶

• Any images, data files, or video recordings of the legal conference as captured on the hand-held camera focused on Ms. Maxwell and counsel during the entirety of the legal conference.

• Any images, data files, or video recordings of the legal conference as captured on surveillance cameras focused on Ms. Maxwell and counsel during the entirety of the legal conference.

• The full names of all guards, including the lieutenant, present in the visiting room during the legal conference.

• Any written or recorded communications, whether stored in electronic, digital or paper format, obtained in connection with the incident identified above.

• A list of all documents claimed to be in Ms. Maxwell’s possession upon entering the visiting room. This request includes copies of any such documents or notes regarding same.

EXHIBIT C¶

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LAW OFFICES OF BOBBI C. STERNHEIM¶

• A list of all documents claimed have been given to Ms. Maxwell by counsel for her retention during the legal conference.

• Any written correspondence, or recorded communications, whether stored in electronic, digital or paper format, created by the guards, staff and other employees of the MDC and BOP.

Please take adequate steps to preserve all documents and data compilations, including electronically stored information (“ESI”), copies and backups, along with any paper files maintained by the MDC relevant to this dispute. ESI should be stored and maintained in its native format.¶

Counsel for Ms. Maxwell will be seeking electronic data in the custody and control of the individuals and entities identified in demand letter that is relevant to this incident, including without limitation, emails and other information contained on computer systems and any electronic storage systems.¶

Counsel for Ms. Maxwell consider the electronic data and paper files and video recordings to be valuable and irreplaceable sources of discoverable information in this matter.¶

Please take all necessary steps to prevent the deletion or destruction of any electronic communications, such as emails, voice mails, or electronic files relating to the above items.¶

Very truly yours,¶

Bobbi C. Sternheim¶

BOBBI C. STERNHEIM¶

2¶

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