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ein was arrested and detained at the Metropolitan Correctional Center ("MCC") on sex trafficking charges, and was subsequently assigned to the MCC's Special Housing Unit ("SHU") due to risk factors for suicide and safety concerns. After an apparent suicide attempt on July 23, 2019, Mr. Epstein was transferred to sui
Case 1:20-cr-00330-AJN Document 38 Filed 08/10/20 Page 1 of 6 COHEN & GRESSER LLP Mark S. Cohen +1 (212) 957-7600 mcohen(cticohengresscr.com Christian R. Everdell +1 (212) 957-7600 [email protected] August 10, 2020 VIA ECF The H
ein was arrested and detained at the Metropolitan Correctional Center ("MCC") on sex trafficking charges, and was subsequently assigned to the MCC's Special Housing Unit ("SHU") due to risk factors for suicide and safety concerns. After an apparent suicide attempt on July 23, 2019, Mr. Epstein was transferred to sui
Case 1:20-cr-00330-AJN Document 38 Filed 08/10/20 Page 1 of 6 COHEN & GRESSER LLP Mark S. Cohen +1 (212) 957-7600 mcohen(cticohengresscr.com Christian R. Everdell +1 (212) 957-7600 [email protected] August 10, 2020 VIA ECF The H
ein was arrested and detained at the Metropolitan Correctional Center ("MCC") on sex trafficking charges, and was subsequently assigned to the MCC's Special Housing Unit ("SHU") due to risk factors for suicide and safety concerns. After an apparent suicide attempt on July 23, 2019, Mr. Epstein was transferred to sui
Page: EFTA00018575 →asons set forth above, we respectfully submit that the Court should grant Ms. Maxwell's motion. Respectfully submitted, /s/ Christian R. Everdell Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP New York, New York 10022 cc: All counsel of record (via ECF) EFTA00018577
Page: EFTA00018577 →Entities connected to both Special Housing Unit and Mark S. Cohen

Jeffrey Epstein
PERSON
Metropolitan Correctional Center
ORGANIZATIONFederal Bureau of Prisons
ORGANIZATION
Ghislaine Maxwell
PERSON
Michael Cohen
PERSON
Department of Justice
ORGANIZATIONSouthern District
LOCATIONReyes
PERSON
Geoffrey S. Berman
PERSON
Prince Andrew
PERSONLeon Black
PERSON
United States
LOCATIONFBI
ORGANIZATIONCohen & Gresser LLP
ORGANIZATIONthe Southern District
LOCATION
Julie K. Brown
PERSON
George W. Bush
PERSON
New York
LOCATION
Colorado
LOCATION
Denver
LOCATION