DOJ-OGR-00004999.pdf

--- Page 1 --- **Document Header** * **Case Number:** 1:20-cr-00330-AJN * **Document Number:** Document 321 * **Filed Date:** 08/19/21 * **Page Number:** Page 2 of 3 * **Law Firm:** LAW OFFICES OF BOBBI C. STERNHEIM **Email Chain** * **Email 1 (August 12th):** By email dated August 12th to MDC Legal, with government counsel copied, I reported that this purported breach severely impacts confidential privileged attorney-client communication and is especially concerning in this high-profile case. I requested that the VTC revert to the original WebEx platform controlled by defense counsel. * **Email 2 (August 13th):** In an email response, dated August 13th, MDC Legal stated: + There was a miscommunication on our end internally. There was no breach. The address provided was a very secure line, however, it was already one being used. We are creating a line as secure as possible. We are hoping for this to be complete by the 9:30 scheduled call, but I cannot confirm it will be ready by then. * **Email 3 (August 16th):** On August 16th, I again emailed MDC Legal, with government counsel copied, requesting clarification as to why the VTC is still not proceeding, as it did not on Friday, and renewed my request that VTCs be reinstated on defense counsel's WebEx platform because the substituted Zoom platform is not secure and seems to have caused cancellation of Ms. Maxwell's VTCs. I also informed MDC Legal, with government counsel copied, that during my in-person visit with Ms. Maxwell on Saturday, August 14th, both Ms. Maxwell and I were told we could not pass documents. This restriction frustrated and affected the productivity of a four-hour visit. **Reply Email** * **Email (Later that day):** In a reply email later that day, MDC Legal stated: + Please understand this is not a simple process and may take a few days. With that said you have had access to your client via telephone. Additionally, as you have had weekend visit on weekend with Ms. Maxwell, we can gladly arrange for the same on any day moving forward. **Additional Information** * **Weekend Legal Visit:** As far as your weekend legal visit- the staff who did not allow the passing of legal documents have been informed of the appropriate instructions. * **Restrictions:** The restrictions placed on Ms. Maxwell, including limiting the quantity of legal documents she may bring to the VTC room or day room and the prohibition on review of documents during in-person legal conferences- coupled with problems with conducting confidential legal conference VTCs - has limited Ms. Maxwell's ability to prepare for trial. Legal calls do not suffice because we cannot share documents. For example, Ms. Maxwell received new discovery today and yet again a significant amount is not viewable on the hardware and software provided by the government. Because we cannot share documents, that discovery remains unviewable by Ms. Maxwell. Further, ongoing delays in bringing Ms. Maxwell to the day room continue, which reduces the time she is permitted to work on her case and limitations. **Page Number** * **Page Number:** 2