9
Shared Docs
8
Same-Page
11 / 9
Mentions
age was caused by the conditions in MDC and not by her. This was recently corroborated by another MDC inmate, Tiffany Days, who explained to Judge McMahon the sorts of conditions that are present at MDC: "I also survived the disgusting feces flood that we were 6 EFTA00089458 actually told to clean
died on BOP's watch and it is going to treat Ms. Maxwell as though she is Epstein. In sentencing another woman who was held at MDC, District Judge Colleen McMahon said the defendant "shouldn't have to suffer for the incompetence of the United States Department of Justice and its subsidiary agency, the Bureau
n sentencing another woman who was held at MDC, District Judge Colleen McMahon said the defendant "shouldn't have to suffer for the incompetence of the United States Department of Justice and its subsidiary agency, the Bureau of Prisons. I will do what I can to bring your situation to the people who, if they give a damn, might do 9
age was caused by the conditions in MDC and not by her. This was recently corroborated by another MDC inmate, Tiffany Days, who explained to Judge McMahon the sorts of conditions that are present at MDC: "I also survived the disgusting feces flood that we were 6 EFTA00096526 Case 21-58. Document 89
died on BOP's watch and it is going to treat Ms. Maxwell as though she is Epstein. In sentencing another woman who was held at MDC, District Judge Colleen McMahon said the defendant "shouldn't have to suffer for the incompetence of the United States Department of Justice and its subsidiary agency, the Bureau
n sentencing another woman who was held at MDC, District Judge Colleen McMahon said the defendant "shouldn't have to suffer for the incompetence of the United States Department of Justice and its subsidiary agency, the Bureau of Prisons. I will do what I can to bring your situation to the people who, if they give a damn, might do 9
imum, this Court Should Order a Hearing at which Maxwell May Inquire into the Circumstances Surrounding the Government's Misrepresentation to Judge McMahon 26 Conclusion 27 Certificate of Service 29 EFTA00077572 Table of Authorities Cases Abdell v. City of New York, No. 05 CIV. 8453 KMK JCF, 20
SA mislead Judge McMahon, Maxwell fully and completely quotes Judge McMahon's question, just as she does above. Mot. at 13 (quoting Ex. E, p 2). " United States Department of Justice, JUSTICE MANUAL, JM § 9-11.151, Grand Jury, Advice of "Rights" of Grand Jury Witnesses (updated Jan. 2020), available at: https://www.justice.govijm
der is unreasonable where, as here, the protective order is on its face temporary or limited." (Id. at 3-4). 6. Proceedings before a. Chief Judge McMahon Mich 26,2019 Hearing Judge Sweet passed away in March 2019 before ruling on the Government's application. After Judge Sweet's death, but before the
ief attended a meeting with defense counsel, during which defense counsel made a pitch that Epstein should not be prosecuted. November 2020 Report, United States Department of Justice, Office of Professional Responsibility, at 61-62. However, although the line prosecutor, , subsequently sent the CEOS Chief a draft of the NPA, the
ces the Instant Investigation in 2018 65 5. The USAO-SDNY's Subpoenas and Ex Pane Applications for Materials 66 6. Proceedings before Chief Judge McMahon 68 a. March 26, 2019 Hearing 68 b. April 9, 2019 Hearing 70 EFTA00077607 c. Chief Judge McMahon's Memorandum and Order 71 7. Magistrate Judge
ief attended a meeting with defense counsel, during which defense counsel made a pitch that Epstein should not be prosecuted. November 2020 Report, United States Department of Justice, Office of Professional Responsibility, at 61-62. However, although the line prosecutor, Maria Villafaiia, subsequently sent the CEOS Chief a draft
ces the Instant Investigation in 2018 65 5. The USAO-SDNY's Subpoenas and Ex Pane Applications for Materials 66 6. Proceedings before Chief Judge McMahon 68 a. March 26, 2019 Hearing 68 b. April 9, 2019 Hearing 70 EFTA00039422 c. Chief Judge McMahon's Memorandum and Order 71 7. Magistrate Judge
ief attended a meeting with defense counsel, during which defense counsel made a pitch that Epstein should not be prosecuted. November 2020 Report, United States Department of Justice, Office of Professional Responsibility, at 61-62. However, although the line prosecutor, Maria Villafaiia, subsequently sent the CEOS Chief a draft
eedin s before 5. The USAO-SDNY's Sub.. nas and Ex Pane Applications for Materials 66 a. M 68 b. April ', 70 EFTA00095068 c. Chief Judge McMahon's Memorandum and Order 71 7. &OAS% 74 8. Unsealing of Maxwell's Depositions 74 9. The New York Daily News Article 75 B. The Defendant's Sup
ief attended a meeting with defense counsel, during which defense counsel made a pitch that Epstein should not be prosecuted. November 2020 Report, United States Department of Justice, Office of Professional Responsibility, at 61-62.6 However, although the line prosecutor, Maria Villafalia, subsequently sent the CEOS Chief a draf
ces the Instant Investigation in 2018 65 5. The USAO-SDNY's Subpoenas and Ex Pane Applications for Materials 66 6. Proceedings before Chief Judge McMahon 68 a. March 26, 2019 Hearing 68 b. April 9, 2019 Hearing 70 EFTA00103000 c. Chief Judge McMahon's Memorandum and Order 71 7. Magistrate Judge
ief attended a meeting with defense counsel, during which defense counsel made a pitch that Epstein should not be prosecuted. November 2020 Report, United States Department of Justice, Office of Professional Responsibility, at 61-62. However, although the line prosecutor, subsequently sent the CEOS Chief a draft of the NPA, the
RAL BUREAU OF PRISONS, Defendant. 20-CV-00833 (PAE) DECLARATION OF KARA CHRISTENSON I, Kara Christenson, declare as follows: I. I am employed by the United States Department of Justice, Federal Bureau of Prisons ("BOP"), as a Government Information Specialist ("GIS") for Central Office, stationed at the Federal Medical Center in R
Page: EFTA00015361 →inmate death and responses thereto, including a memorandum; a document titled MCC New York Updates; draft letters to Epstein's brother, Chief Judge McMahon and Judge Berman; a letter to the MCC warden dated August 14, 2019; photo sheets from Epstein's July 23, 2019 apparent suicide attempt and Epstein'
Page: EFTA00015374 →Entities connected to both Colleen McMahon and United States Department of Justice

Jeffrey Epstein
PERSON
Department of Justice
ORGANIZATION
Ghislaine Maxwell
PERSONthe Southern District
LOCATION
United States
LOCATIONFBI
ORGANIZATION
Southern District of New York
ORGANIZATION
Prince Andrew
PERSON
Bradley Edwards
PERSON
George W. Bush
PERSONMartin Weinberg
PERSONJane Doe
PERSON
Geoffrey S. Berman
PERSON
Alexander Acosta
PERSON
Julie K. Brown
PERSONLeon Black
PERSON
Bill Clinton
PERSONMaria Farmer
PERSON
Scarlett Johansson
PERSON
Alan Dershowitz
PERSON