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cting her ability to prepare for and withstand trial. The Court sought more information by ordering the Government to confer with legal counsel for the Bureau of Prisons and to respond to certain questions. Dkt. No. 257. In response, the Government states that MDC staff conduct flashlight checks of all inmates as a
ct Court for the Southern District of New York, 20-CR-330 (AJN) Appellant Ghislaine Maxwell's Appendix to the Renewed Motion for Pretrial Release Leah S. Saffian LAW OFFICES OF LEAH SAFFIAN 15546 Meadowgate Road Encino, California 91436-3429 Tel: (858)488-2765 David Oscar Markus *Counsel of Record MARKU
e her stress instead of exacerbate it. Ms. Maxwell replied. Ex. E, Doc. 272. The district court then issued an order saying that it would not tell the Bureau of Prisons what to do but "admonishe[d] the MDC and the Government to continue to ensure that Maxwell is subjected to only those security protocols that BOP d
ed States District Court for the Southern District of New York, 20-CR-330 (AJN) Appellant Ghislaine Maxwell's Renewed Motion for Pretrial Release Leah S. Saffian David Oscar Markus LAW OFFICES OF LEAH SAFFIAN *Counsel of Record ME- markuslaw.com EFTA00089452 Appellant Ghislaine Maxwell's Renewed Motion
e her stress instead of exacerbate it. Ms. Maxwell replied. Ex. E, Doc. 272. The district court then issued an order saying that it would not tell the Bureau of Prisons what to do but "admonishe[d] the MDC and the Government to continue to ensure that Maxwell is subjected to only those security protocols that BOP d
ed States District Court for the Southern District of New York, 20-CR-330 (AJN) Appellant Ghislaine Maxwell's Renewed Motion for Pretrial Release Leah S. Saffian LAW OFFICES OF LEAH SAFFIAN 15546 Meadowgate Road Encino, California 91436-3429 Tel: (858)488-2765 David Oscar Markus *Counsel of Record MARKU
Entities connected to both Federal Bureau of Prisons and Leah S. Saffian

Jeffrey Epstein
PERSON
Department of Justice
ORGANIZATIONSpecial Housing Unit
ORGANIZATION
Ghislaine Maxwell
PERSONthe Southern District
LOCATION
United States
LOCATION
William Barr
PERSON
Prince Andrew
PERSON
George W. Bush
PERSON
United States Department of Justice
ORGANIZATION
Audrey Strauss
PERSON
Alison J. Nathan
PERSON
the United States District Court
ORGANIZATIONColleen McMahon
PERSON
ALISON J. NATHAN
ORGANIZATIONthe United States Court of Appeals
ORGANIZATION
Tiffany Trump
PERSONthe City of New York
LOCATION
Century
ORGANIZATIONMDC Brooklyn's
ORGANIZATION