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nths in isolation, Ms. Maxwell has had to watch as she has been relentlessly attacked in a deluge of media articles that spiked over a year ago when Epstein 2 Ms. Maxwell has not yet signed these waivers because we have not been able to visit her in the MDC to obtain her signature since she was quaranti
Maxwell's renewed bail application. (See Exs. A-N, W-X). Far from the cruel caricature that the press has so recklessly depicted since the arrest of Jeffrey Epstein, these letters demonstrate that Ms. Maxwell is generous, loving, and devoted to her family and friends, and that her life is firmly rooted in this
the Ghislaine I know is a wonderful and loving on. Until the explosion of media interest that followed the arrest and subs uent death in custod of Jeffre E tein in Jul thru Au t 2019 (Id. ¶¶ 4-5). The letters from Ms. Maxwell's family members similarly describe how Ms. Maxwell's home is in the United
ohen Christian R. Everdell COHEN & GRESSER LLP Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &
een October 2015 and June 2019. It was not until Mr. Epstein's arrest in July 2019 that Ms. Maxwell was thrown
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
nths in isolation, Ms. Maxwell has had to watch as she has been relentlessly attacked in a deluge of media articles that spiked over a year ago when Epstein 2 Ms. Maxwell has not yet signed these waivers because we have not been able to visit her in the MDC to obtain her signature since she was quaranti
Maxwell's renewed bail application. (See Exs. A-N, W-X). Far from the cruel caricature that the press has so recklessly depicted since the arrest of Jeffrey Epstein, these letters demonstrate that Ms. Maxwell is generous, loving, and devoted to her family and friends, and that her life is firmly rooted in this
the Ghislaine I know is a wonderful and loving on. Until the explosion of media interest that followed the arrest and subs uent death in custod of Jeffre E tein in Jul thru Au t 2019 (Id. ¶¶ 4-5). The letters from Ms. Maxwell's family members similarly describe how Ms. Maxwell's home is in the United
ohen Christian R. Everdell COHEN & GRESSER LLP Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &
een October 2015 and June 2019. It was not until Mr. Epstein's arrest in July 2019 that Ms. Maxwell was thrown
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
public eye, not because she was trying to evade law enforcement, but because the intense media frenzy and threats following the arrest and death of Jeffrey Epstein threatened the safety and wellbeing of herself and her family, especially the minor children. For these same reasons, Ms. Maxwell's spouse did not
nths in isolation, Ms. Maxwell has had to watch as she has been relentlessly attacked in a deluge of media articles that spiked over a year ago when Epstein 2 Ms. Maxwell has not yet signed these waivers because we have not been able to visit her in the MDC to obtain her signature since she was quaranti
COHEN & GRESSER LLP New York, NY 10022 Phone: Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &
een October 2015 and June 2019. It was not until Mr. Epstein's arrest in July 2019 that Ms. Maxwell was thrown
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
ake personal calls, and the opportunity to exercise and shower. Clearly, this was an effort to avoid a recurrence of the BOP's negligence regarding Jeffrey Epstein's death. Contrary to the way she is hyper-monitored, Ms. Maxwell is classified with the standard CC I-Mh designation: inmate with no significant ment
BOP negligence resulting in the death of Jeffrey Epstein. EFTA00091824 LAW OFFICES OF BOBBI C. STERNHEI
ctly to BOP negligence resulting in the death of Jeffrey Epstein. EFTA00091824 LAW OFFICES OF BOBBI C.
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
ne 29, 2020. a grand jury in the Southern District of New York returned a six-count Indictment against the Defendant, charging her with facilitating Jeffrey Epstein's sexual abuse of multiple minor victims between approximately 1994 and 1997. See Dkt. No. 1. On July 2, 2020, the Indictment was unsealed, and that
t 30 years, might flee to the United Kingdom or France if granted bail, despite the fact that she did not leave the country for nearly a year after Epstein's arrest. (Dkt. 22 at 6.) The government asserted in its reply brief that France "does not extradite its citizens to the United States pursuant to F
eve of the one-year anniversary of the arrest of Jeffrey Epstein, creating the misimpression that Ms. Maxw
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
ake personal calls, and the opportunity to exercise and shower. Clearly, this was an effort to avoid a recurrence of the BOP's negligence regarding Jeffrey Epstein's death. Contrary to the way she is hyper-monitored, Ms. Maxwell is classified with the standard CC I-Mh designation: inmate with no significant ment
s persuasively argued that the Non-Prosecution Agreement entered into by Jeffrey Epstein in 2007, which immunizes "any potential co-conspirators of Epstein," bars Ms. Maxwell's prosecution in this case, and that the counts charging her with alleged sexual abuse are time-barred. The government's respon
LP 800 Third Avenue New York, NY 10022 Phone: Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &
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
Entities connected to both Jeffrey Epstein and MDC Legal

Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
John F. Kennedy
PERSON
George W. Bush
PERSON
United States
LOCATION
Stephen Hawking
PERSON
Michael Cohen
PERSON
Department of Justice
ORGANIZATION
Alfredo Rodriguez
PERSONthe Southern District
LOCATION
Harvey Weinstein
PERSON
David Boies
PERSON
Denver
LOCATION
Vicky Ward
PERSON
Southern District of New York
ORGANIZATIONJeffrey Pagliuca
PERSON
United Kingdom
LOCATIONJulie
PERSONSecond Circuit
ORGANIZATION
New Hampshire
LOCATION