Epstein Secrets

New York, NY 10022 Phone: Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver, CO 80203 Phone: Bobbi C. Sternheim Law Offices of Bobbi C. Stemheim 33 West 19th Street - 4th Floor New York, NY 10011 Phone: Attorneys for Ghislaine Maxwell EFTA00093305 Cgase

itions, counsel requested that the Warden provide a first-hand report to the Court and counsel. Following Court directive for a report from the MDC, MDC Legal submitted a letter that recited BOP policy but failed to address a number of concerns. 36 EFTA00093257 Ccosel.211-ZMICERWlit Meutiskfit19302Frii

Defendant. x 20 Cr. 330 (AJN) MEMORANDUM IN SUPPORT OF GHISLAINE MAXWELL'S THIRD MOTION FOR RELEASE ON BAIL Bobbi C. Sternheim Law Offices of Bobbi C. Sternheim 33 West 19th Street - 4th Floor New York, NY 10011 Phone: Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone

xtent to which she is required to undergo searches. The government's letter, however, does not include the concerns defense counsel has reported to MDC Legal during the past couple of months. In addition, the letter incorrectly states that legal calls are available on Saturdays. Such requests by counsel

onitor. She alerted MDC staff, and Case Manageretnessed the activity. This is contrary to the Court's finding that "according to the Government and MDC Legal [Ms. Maxwell]'s difficulties communicating with counsel have been resolved" and contrary to "MDC's Legal assurances that [Ms. Maxwell]'s legal comm

--- PAGE BREAK --- *Please note my new office address and preferred email address: Please note my new office address and preferred email address: BOBBI C. STERNHEIM, ESQ. Law Offices of Bobbi C. Stemheim 225 Broadway, Suite 715 New York, NY 10007 Main: 212-243-1100 Cell: 917-912-9698 Fax: 888-587-4737 bcst