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mation and belief, decisions concerning Ms. Maxwell's specialized detention are made by Warden Tellez, or from others outside the MDC. A report from the MDC Legal Department would provide second-hand information. Accordingly, Warden Tellez should be directed to provide a first-hand accounting to the Court and counsel wh
sel. The Government has also conferred with defense counsel three times regarding the same, as well as the defense's request relating to MDC Warden Heriberto Tellez. The parties have been unable to reach agreement. Our respective positions follow. The Government respectfully submits that the Court should allow
mation and belief, decisions concerning Ms. Maxwell's specialized detention are made by Warden Tellez, or from others outside the MDC. A report from the MDC Legal Department would provide second-hand information. Accordingly, Warden Tellez should be directed to provide a first-hand accounting to the Court and counsel wh
sel. The Government has also conferred with defense counsel three times regarding the same, as well as the defense's request relating to MDC Warden Heriberto Tellez. The parties have been unable to reach agreement. Our respective positions follow. The Government respectfully submits that the Court should allow
sel. The Government has also conferred with defense counsel three times regarding the same, as well as the defense's request relating to MDC Warden Heriberto Tellez. The parties have been unable to reach agreement. Our respective positions follow. The Government respectfully submits that the Court should allow
Page: EFTA00010196 →mation and belief, decisions concerning Ms. Maxwell's specialized detention are made by Warden Tellez, or from others outside the MDC. A report from the MDC Legal Department would provide second-hand information. Accordingly, Warden Tellez should be directed to provide a first-hand accounting to the Court and counsel wh
Page: EFTA00010197 →sel. The Government has also conferred with defense counsel three times regarding the same, as well as the defense's request relating to MDC Warden Heriberto Tellez. The parties have been unable to reach agreement. Our respective positions follow. The Government respectfully submits that the Court should allow
Page: EFTA00027270 →mation and belief, decisions concerning Ms. Maxwell's specialized detention are made by Warden Tellez, or from others outside the MDC. A report from the MDC Legal Department would provide second-hand information. Accordingly, Warden Tellez should be directed to provide a first-hand accounting to the Court and counsel wh
Page: EFTA00027271 →Entities connected to both the MDC Legal Department and Heriberto Tellez

Ghislaine Maxwell
PERSON
Alison J. Nathan
PERSON
Prince Andrew
PERSON
Audrey Strauss
PERSON
Department of Justice
ORGANIZATION
Michael Cohen
PERSON
Warden Tellez
PERSONCohen & Gresser LLP
ORGANIZATION
Christian Everdell
PERSONSouthern District
LOCATION
Christian R. Everdell
PERSON
ALISON J. NATHAN
ORGANIZATION
New York City
LOCATIONFederal Bureau of Prisons
ORGANIZATIONThe MDC Brooklyn
ORGANIZATIONthe Metropolitan Detention Center
ORGANIZATIONTellez
PERSONthe Federal Defenders
ORGANIZATIONThe Silvio J. Mollo Building
ORGANIZATIONHealth Services
ORGANIZATION