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navirus cases.; In particular, COVID-19 has begun to spread through the Metropolitan Detention Center (MDC), where Ms. Maxwell has been housed since the Bureau of Prisons (BOP) transferred her there on July 6, 2020. According to the MDC's statistics, as of April 3, 2020, two inmates and I Timothy Williams, et al., Co
internal quotation marks omitted). 8 See also Letter of Sean Hecker to Hon. Margo K. Brodie (July 8, 2020), Federal Defenders of New York, Inc. v. Federal Bureau of Prisons, et at, No. 19 Civ. 660 (E.D.N.Y.) (Doc. No. 78) (detailing absence of in-person visitation, highly limited VTC and telephone call capacity, and iss
ends and professional colleagues who reside in this country. In sum, the United States has been Ms. Maxwell's home for decades. b. Ms. Maxwell Has Actively Litigated Civil Cases in this District and Has Not Left the United States Since Epstein's 2019 Arrest Ms. Maxwell has never once attempted to "hide" from the government
navirus cases.; In particular, COVID-19 has begun to spread through the Metropolitan Detention Center (MDC), where Ms. Maxwell has been housed since the Bureau of Prisons (BOP) transferred her there on July 6, 2020. According to the MDC's statistics, as of April 3, 2020, two inmates and I Timothy Williams, et al., Co
internal quotation marks omitted). 8 See also Letter of Sean Hecker to Hon. Margo K. Brodie (July 8, 2020), Federal Defenders of New York, Inc. v. Federal Bureau of Prisons, et at, No. 19 Civ. 660 (E.D.N.Y.) (Doc. No. 78) (detailing absence of in-person visitation, highly limited VTC and telephone call capacity, and iss
ends and professional colleagues who reside in this country. In sum, the United States has been Ms. Maxwell's home for decades. b. Ms. Maxwell Has Actively Litigated Civil Cases in this District and Has Not Left the United States Since Epstein's 2019 Arrest Ms. Maxwell has never once attempted to "hide" from the government
navirus cases.; In particular, COVID-19 has begun to spread through the Metropolitan Detention Center (MDC), where Ms. Maxwell has been housed since the Bureau of Prisons (BOP) transferred her there on July 6, 2020. According to the MDC's statistics, as of April 3, 2020, two inmates and I Timothy Williams, et al., Co
internal quotation marks omitted). 8 See also Letter of Sean Hecker to Hon. Margo K. Brodie (July 8, 2020), Federal Defenders of New York, Inc. v. Federal Bureau of Prisons, et at, No. 19 Civ. 660 (E.D.N.Y.) (Doc. No. 78) (detailing absence of in-person visitation, highly limited VTC and telephone call capacity, and iss
ends and professional colleagues who reside in this country. In sum, the United States has been Ms. Maxwell's home for decades. b. Ms. Maxwell Has Actively Litigated Civil Cases in this District and Has Not Left the United States Since Epstein's 2019 Arrest Ms. Maxwell has never once attempted to "hide" from the government
navirus cases.; In particular, COVID-19 has begun to spread through the Metropolitan Detention Center (MDC), where Ms. Maxwell has been housed since the Bureau of Prisons (BOP) transferred her there on July 6, 2020. According to the MDC's statistics, as of April 3, 2020, two inmates and I Timothy Williams, et al., Co
internal quotation marks omitted). 8 See also Letter of Sean Hecker to Hon. Margo K. Brodie (July 8, 2020), Federal Defenders of New York, Inc. v. Federal Bureau of Prisons, et at, No. 19 Civ. 660 (E.D.N.Y.) (Doc. No. 78) (detailing absence of in-person visitation, highly limited VTC and telephone call capacity, and iss
ends and professional colleagues who reside in this country. In sum, the United States has been Ms. Maxwell's home for decades. b. Ms. Maxwell Has Actively Litigated Civil Cases in this District and Has Not Left the United States Since Epstein's 2019 Arrest Ms. Maxwell has never once attempted to "hide" from the government
navirus cases.; In particular, COVID-19 has begun to spread through the Metropolitan Detention Center (MDC), where Ms. Maxwell has been housed since the Bureau of Prisons (BOP) transferred her there on July 6, 2020. According to the MDC's statistics, as of April 3, 2020, two inmates and I Timothy Williams, et al., Co
internal quotation marks omitted). 8 See also Letter of Sean Hecker to Hon. Margo K. Brodie (July 8, 2020), Federal Defenders of New York, Inc. v. Federal Bureau of Prisons, et at, No. 19 Civ. 660 (E.D.N.Y.) (Doc. No. 78) (detailing absence of in-person visitation, highly limited VTC and telephone call capacity, and iss
ends and professional colleagues who reside in this country. In sum, the United States has been Ms. Maxwell's home for decades. b. Ms. Maxwell Has Actively Litigated Civil Cases in this District and Has Not Left the United States Since Epstein's 2019 Arrest Ms. Maxwell has never once attempted to "hide" from the government
navirus cases.; In particular, COVID-19 has begun to spread through the Metropolitan Detention Center (MDC), where Ms. Maxwell has been housed since the Bureau of Prisons (BOP) transferred her there on July 6, 2020. According to the MDC's statistics, as of April 3, 2020, two inmates and I Timothy Williams, et al., Co
internal quotation marks omitted). 8 See also Letter of Sean Hecker to Hon. Margo K. Brodie (July 8, 2020), Federal Defenders of New York, Inc. v. Federal Bureau of Prisons, et at, No. 19 Civ. 660 (E.D.N.Y.) (Doc. No. 78) (detailing absence of in-person visitation, highly limited VTC and telephone call capacity, and iss
ends and professional colleagues who reside in this country. In sum, the United States has been Ms. Maxwell's home for decades. b. Ms. Maxwell Has Actively Litigated Civil Cases in this District and Has Not Left the United States Since Epstein's 2019 Arrest Ms. Maxwell has never once attempted to "hide" from the government
and internal quotation marks omitted). See also Letter of Sean Hecker to Hon. Margo K. Brodie (July 8, 2020), Federal Defenders of New York Inc. v. Federal Bureau of Prisons, et at, No. 19 Civ. 660 (E.D.N.Y.) (Doc. No. 78) (detailing absence of in-person visitation, highly limited VTC and telephone call capacity, and iss
ends and professional colleagues who reside in this country. In sum, the United States has been Ms. Maxwell's home for decades. b. Ms. Maxwell Has Actively Litigated Civil Cases in this District and Has Not Left the United States Since Epstein's 2019Arrest Ms. Maxwell has never once attempted to "hide" from the government o
Entities connected to both Federal Bureau of Prisons and Actively Litigated Civil Cases

Jeffrey Epstein
PERSON
Metropolitan Correctional Center
ORGANIZATION
Ghislaine Maxwell
PERSONthe Southern District
LOCATION
United States
LOCATION
Michael Jackson
PERSON
Stephen Hawking
PERSON
Michael Cohen
PERSON
Colorado
LOCATION
Bernie Sanders
PERSON
Southern District of New York
ORGANIZATIONSecond Circuit
ORGANIZATION
Houston
LOCATIONthe Metropolitan Detention Center
ORGANIZATION
United Kingdom
LOCATION
Bernie Madoff
PERSON
The New York Times
ORGANIZATION
Denver
LOCATIONJeffrey Pagliuca
PERSON
Mattis
PERSON