4
Shared Docs
2
Same-Page
4 / 4
Mentions
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
tions or require any additional details regarding this topic, the Government will promptly provide additional information. Respectfully submitted, AUDREY STRAUSS Acting United States Attorney By: Cc: All Counsel of Record (By ECF) Assistant United States Attorneys Southern District of New York Tel: EFTA
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
ounsel why Ms. Maxwell is being detained under such individualized conditions. Your consideration is greatly appreciated. Respectfully submitted, AUDREY STRAUSS Acting United States Attorney By: 5/ Assistant United States Attorneys Southern District of New York Tel: Cc: All Counsel of Record (By ECF) E
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 →ounsel why Ms. Maxwell is being detained under such individualized conditions. Your consideration is greatly appreciated. Respectfully submitted, AUDREY STRAUSS Acting United States Attorney By: Assistant United States Attorneys Southern District of New York Tel: Cc: All Counsel of Record (By ECF) MDC
Page: EFTA00010197 →tions or require any additional details regarding this topic, the Government will promptly provide additional information. Respectfully submitted, AUDREY STRAUSS Acting United States Attorney By: Maurene Comey / Alison Moe / Lara Pomerantz Assistant United States Attorneys Southern District of New York T
Page: EFTA00027269 →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 →Entities connected to both Heriberto Tellez and Audrey Strauss

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Prince Andrew
PERSON
Department of Justice
ORGANIZATION
Michael Cohen
PERSONSouthern District
LOCATION
Alison J. Nathan
PERSONJeffrey Pagliuca
PERSONLaura Menninger
PERSON
Christian Everdell
PERSONCohen & Gresser LLP
ORGANIZATIONThe Silvio J. Mollo Building
ORGANIZATIONFederal Bureau of Prisons
ORGANIZATIONBobbi C. Sternheim
PERSONthe Metropolitan Detention Center
ORGANIZATION
New York City
LOCATION
ALISON J. NATHAN
ORGANIZATIONthe MDC Legal Department
ORGANIZATION
Warden Tellez
PERSONTellez
PERSON