DOJ-OGR-00004992.pdf

--- Page 1 --- **Document Header** * Case Number: 1:20-cr-00330-PAE * Document Number: 319 * Filed Date: 08/18/21 * Page Number: 2 of 3 * Law Offices of Bobbi C. Sternheim **Email Exchange** * **Email 1** + Date: August 12th + To: MDC Legal + From: [Unknown] + Subject: [Not specified] + Content: This breach was reported to, and I believe witnessed by, MDC staff, including an MDC technician named Leon who is tasked with dealing with Ms. Maxwell's electronics issues. + Additional Information: 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** + Date: August 13th + To: MDC Legal + From: [Unknown] + Subject: [Not specified] + Content: 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. + Additional Information: 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. * **Email 3** + Date: [Not specified] + To: MDC Legal + From: [Unknown] + Subject: [Not specified] + Content: 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: 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. **Footer** * DOJ-OGR-00004992