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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
in which defendants of lesser means are detained pending trial while wealthy defendants are released to self-funded private jails." United States v. Boustani, 932 F.3d 79, 82 (2d Cir. 2019). As in Boustani, the Defendant in the present case would be detained regardless of her wealth, and "if a similarly
pending trial while wealthy defendants are released to self-funded private jails." United States v. Boustani, 932 F.3d 79, 82 (2d Cir. 2019). As in Boustani, the Defendant in the present case would be detained regardless of her wealth, and "if a similarly situated defendant of lesser means would be deta
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 EFTA00065757 alerted the government on August 27, 2020
s. Maxwell's Health and Ability to Prepare Her Defense 35 CONCLUSION 38 ii EFTA00065718 TABLE OF AUTHORITIES Page(s) Cases United States v. Boustani, 932 F.3d 79 (2d Cir. 2019) 3 United States v. Bradshaw, No. 0040033-04-DES, 2000 WL 1371517 (D. Kan. July 20, 2000) 8 United States v. Chen,
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 EFTA00154553 alerted the government on August 27, 2020
s. Maxwell's Health and Ability to Prepare Her Defense 35 CONCLUSION 38 ii EFTA00154514 TABLE OF AUTHORITIES Page(s) Cases United States v. Boustani, 932 F.3d 79 (2d Cir. 2019) 3 United States v. Bradshaw, No. 0040033-04-DES, 2000 WL 1371517 (D. Kan. July 20, 2000) 8 United States v. Chen,
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 EFTA00094330 alerted the government on August 27, 2020
s. Maxwell's Health and Ability to Prepare Her Defense 35 CONCLUSION 38 ii EFTA00094291 TABLE OF AUTHORITIES Page(s) Cases United States v. Boustani, 932 F.3d 79 (2d Cir. 2019) 3 United States v. Bradshaw, No. 0040033-04-DES, 2000 WL 1371517 (D. Kan. July 20, 2000) 8 United States v. Chen,
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
United States v. Bohn, 330 F. Supp. 2d 960 (W.D. Tenn. 2004) 15 United States v. Bolero, 604 F. Supp. 1028 (S.D. Fla. 1985) 15 United States v. Boustani, 356 F. Supp. 3d 246 (E.D.N.Y.), aff'd, No. 19-344, 2019 WL 2070656 (2d Cir. Mar. 7, 2019) 28 United States v. Boustani, 932 F.3d 79 (2d Or. 2019)
Entities connected to both MDC Legal and Boustani

Ghislaine Maxwell
PERSON
Jeffrey Epstein
PERSON
United States
LOCATIONthe Southern District
LOCATION
Michael Cohen
PERSON
Southern District of New York
ORGANIZATIONSecond Circuit
ORGANIZATIONKarni
PERSON
Department of Justice
ORGANIZATION
United Kingdom
LOCATION
Mattis
PERSON
Stephen Hawking
PERSONPetrov
PERSONJeffrey Pagliuca
PERSONKhashoggi
PERSON
Prince Andrew
PERSONRaniere
PERSONSalvagno
PERSONCohen & Gresser LLP
ORGANIZATIONMark S. Cohen
PERSON