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of New York 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Judge Nathan: BOO Thad Avenue New Yak, NY 10022 +1 212 957 7600 phone oeww.cohengesser cool On behalf of our client, Ghislaine Maxwell, we plan to file a Renewed Motion for Release on
m to address these issues and other confidentiality concerns related to the Motion. We intend to provide a full set of materials to the government, Pretrial Services, and the Court when the Motion is filed. We are merely requesting that sensitive contents of the submission be accorded confidentiality protections
of New York 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Judge Nathan: BOO Thad Avenue New Yak, NY 10022 +1 212 957 7600 phone oeww.cohengesser cool On behalf of our client, Ghislaine Maxwell, we plan to file a Renewed Motion for Release on
m to address these issues and other confidentiality concerns related to the Motion. We intend to provide a full set of materials to the government, Pretrial Services, and the Court when the Motion is filed. We are merely requesting that sensitive contents of the submission be accorded confidentiality protections
and their other co-conspirators have attempted to thwart their victims from obtaining justice for decades." ita Gn,ibine Mcomen of Soong Sodom in New Yak Ca% OK 18, 2016. Patnck McMullan via Getty Images. file Maxwell, 58, is the Oxford-educated daughter of Robert Maxwell, the larger than life publi
ted to the Southern and Eastern Districts of New York; (iii) surrender of all travel documents with no new applications; (iv) strict supervision by Pretrial Services; (v) home confinement at a residence in the Southern District of New York with electronic CPS monitoring; (vi) visitors limited to Ms. Maxwell's imm
Entities connected to both New Yak and Pretrial Services

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
New York City
LOCATION
Michael Cohen
PERSON
New York
LOCATIONMartin Weinberg
PERSON
Julie K. Brown
PERSONFBI
ORGANIZATION
Michael Jackson
PERSONthe Southern District
LOCATION
Harry Reid
PERSON
George Mitchell
PERSON
Department of Justice
ORGANIZATION
Prince Andrew
PERSON
U.S. Virgin Islands
LOCATION
New York State
LOCATIONSecond Circuit
ORGANIZATION
Samantha Power
PERSON
Marc Rich
PERSON