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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
MDC warden, dated October 29, 2020, which details the most serious and extraordinarily restrictive conditions of confinement. 12 These include: ■ De Facto Solitary Confinement ■ Excessive Surveillance ■ Excessive Scanning and Strip Searching ■ Deprivation of Food ■ Deprivation of Sleep ■ Deprivation of Communicati
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
MDC warden, dated October 29, 2020, which details the most serious and extraordinarily restrictive conditions of confinement. 12 These include: ■ De Facto Solitary Confinement ■ Excessive Surveillance ■ Excessive Scanning and Strip Searching ■ Deprivation of Food ■ Deprivation of Sleep ■ Deprivation of Communicati
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
MDC warden, dated October 29, 2020, which details the most serious and extraordinarily restrictive conditions of confinement. 12 These include: ■ De Facto Solitary Confinement ■ Excessive Surveillance ■ Excessive Scanning and Strip Searching ■ Deprivation of Food ■ Deprivation of Sleep ■ Deprivation of Communicati
avoid the catastrophic consequences of negligence occurring at the Metropolitan Correctional Center (MCC- Manhattan) which resulted in the death of Jeffrey Epstein. The Attorney General of the United States has said as much. The BOP has admitted that the sanctions are not in response to a specific threat that M
tacitly suggests the heightened restrictions are in response to the high-profile nature of the case and the acknowledged failure by the BOP to keep Epstein — an actual threat to himself — alive. As ABC News reported: Attorney General William Barr told ABC News on Wednesday that he is keeping a close wa
ccurring at the MCC that resulted in the death of Jeffrey Epstein. The Attorney General of the United Stat
e her opportunity to confer with counsel and prepare her defense for trial and are detrimental to her physical health and psychological well-being: De Facto Solitary Confinement: Ms. Maxwell is the sole inmate in a housing unit. By this Court's order she is permitted out of her approximately 9-by-7-foot isolation cell from 7
Entities connected to both Jeffrey Epstein and De Facto Solitary Confinement

Ghislaine Maxwell
PERSON
George W. Bush
PERSON
United States
LOCATION
Stephen Hawking
PERSON
Michael Cohen
PERSONthe Southern District
LOCATION
Harvey Weinstein
PERSON
Vicky Ward
PERSONJeffrey Pagliuca
PERSONJulie
PERSONSecond Circuit
ORGANIZATION
New Hampshire
LOCATIONCohen & Gresser LLP
ORGANIZATION
Bill Cosby
PERSON
Denmark
LOCATIONJoaquin
PERSONEl Chapo
PERSON
LexisNexis
ORGANIZATIONMark S. Cohen
PERSONR. Everdell
PERSON