Epstein Secrets

han United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Judge Nathan: We write to respectfully request the Court to issue an order to the MDC directing it to accept two hard drives

rder to the MDC directing it to accept two hard drives from defense counsel that contain the non-Highly Confidential discovery in this case for Ms. Maxwell's use at the MDC. In an effort to facilitate Ms. Maxwell's review of the discovery, defense counsel have created a master set of two hard drives th

Square New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Judge Nathan: We

n-Highly Confidential discovery in this case for Ms. Maxwell's use at the MDC. In an effort to facilitate Ms.

countless hours to her review. Defense counsel would like to send these hard drives to Ms. Maxwell for her to use in the MDC. We were informed by the MDC Legal Department that they are only permitted to accept hard drives that are loaded and certified by the U.S. Attorney's Office. We have conferred with the governme

urthouse USDC SONY DOCUMENT ELECTRONICALLY FILED DOC 0: DATE FILED: 5/3/21 April 30, 2021 9D OltOUID. ALIION I. mama I Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Judge Nathan: SOO Thad Avenue New Yolk. NY 10022 ♦1 212 957 7600 phono www cohongartav corn Counsel for the MDC may subm

rder to the MDC directing it to accept two hard drives from defense counsel that contain the non-Highly Confidential discovery in this case for Ms. Maxwell's use at the MDC. In an effort to facilitate Ms. Maxwell's review of the discovery, defense counsel have created a master set of two hard drives th

OltOUID. ALIION I. mama I Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Judge Nathan: SOO

n-Highly Confidential discovery in this case for Ms. Maxwell's use at the MDC. In an effort to facilitate Ms.

countless hours to her review. Defense counsel would like to send these hard drives to Ms. Maxwell for her to use in the MDC. We were informed by the MDC Legal Department that they are only permitted to accept hard drives that are loaded and certified by the U.S. Attorney's Office. We have conferred with the governme

use 40 Foley Square New York, NY 10007 USDC SONY DOCUMENT ELECTRONICALLY PILED DOC 0: DATE FILED: 5/3/21 April 30, 2021 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Judge Nathan: eop Th,rd Avenue New Ycek. NY 10022 +1 212%7 7600 phono ‘..vay.cohonsrossof corn Counsel for the MDC may s

rder to the MDC directing it to accept two hard drives from defense counsel that contain the non-Highly Confidential discovery in this case for Ms. Maxwell's use at the MDC. In an effort to facilitate Ms. Maxwell's review of the discovery, defense counsel have created a master set of two hard drives th

LED: 5/3/21 April 30, 2021 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Judge Nathan: eop

n-Highly Confidential discovery in this case for Ms. Maxwell's use at the MDC. In an effort to facilitate Ms.

countless hours to her review. Defense counsel would like to send these hard drives to Ms. Maxwell for her to use in the MDC. We were informed by the MDC Legal Department that they are only permitted to accept hard drives that are loaded and certified by the U.S. Attorney's Office. We have conferred with the governme

NY 10007 Dear Judge Nathan: 33 West 19th Street - 4th Floor New York, New York 10011 [email protected] December 7, 2020 Re: United States v. Ghislaine Maxwell 20 Cr. 330 (AJN) As counsel for Ghislaine Maxwell, we write in response to the letter from MDC staff attorneys. (See Dkt. 8k) The letter fails to

it for the Court's consideration. (See Exhibit A.) We renew our request that Warden respond directly to the Court and counsel and explain why Ms. Maxwell must be detained under such harsh and restrictive conditions. Using the term "[lin her current assignment," the letter attempts to present a pictur

lmlow.com December 7, 2020 Re: United States v. Ghislaine Maxwell 20 Cr. 330 (AJN) As counsel for Ghislai

irectly to the Court and counsel and explain why Ms. Maxwell must be detained under such harsh and restrictiv

any other detainee, deserves. We continue our ongoing attempt to resolve these matters without court intervention. We have voiced complaint through the MDC Legal Department, your office, the AUSAs in charge of this case, and the Federal Defenders of New York.3 Ms. Maxwell has attempted to resolve these matters by follo

ited States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully submits this letter to provide an update regarding the defendant's conditions of

Government, the defense's position is as follows: Warden Heriberto Tellez should appear before the Court to directly address concerns regarding Ms. Maxwell's conditions of confinement, which specifically target her. On October 29, 2020, the defense emailed a letter to Warden Tellez detailing the onerous

DNY DOCUMENT ELECTRONICALLY FILED DOC 0: DATE FILED: 12/7/20 This letter is written in response to your order dated December 2, 2020, concerning Ghislaine Maxwell, Reg. 02879-509., an inmate currently confined at the Metropolitan Detention center in Brooklyn, New York. You expressed various concerns r

the Court to directly address concerns regarding Ms. Maxwell's conditions of confinement, which specifically t

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

ited States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The parties jointly submit this letter in response to the Court's November 24, 2020 order directing the parti

Government, the defense's position is as follows: Warden Heriberto Tellez should appear before the Court to directly address concerns regarding Ms. Maxwell's conditions of confinement, which specifically target her. On October 29, 2020, the defense emailed a letter to Warden Tellez detailing the onerous

DNY DOCUMENT ELECTRONICALLY FILED DOC 0: DATE FILED: 12/7/20 This letter is written in response to your order dated December 2, 2020, concerning Ghislaine Maxwell, Reg. 02879-509., an inmate currently confined at the Metropolitan Detention center in Brooklyn, New York. You expressed various concerns r

the Court to directly address concerns regarding Ms. Maxwell's conditions of confinement, which specifically t

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

ited States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: USDC SONY DOCUMENT ELECTRONICALLY FILED DOC 0: DATE FILED: 1212120 The parties jointly submit this letter

unicated to the Government, the defense's position is as follows: Warden should appear before the Court to directly address concerns regarding Ms. Maxwell's conditions of confinement which specifically target her. On October 29, 2020, the defense emailed a letter to Warden detailing the onerous and re

New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: US

the Court to directly address concerns regarding Ms. Maxwell's conditions of confinement which specifically ta

Upon informal, belief, decisions concerning Ms. Maxwell's specialized detention are made by Warden or from others outside the MDC. A report from the MDC Legal Department would provide second-hand information. Accordingly, Warden should be directed to provide a first-hand accounting to the Court and counsel why Ms.

use 40 Foley Square New York, NY 10007 USDC SONY DOCUMENT ELECTRONICALLY FILED DOC 0: DATE FILED: 5/3/21 April 30, 2021 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Judge Nathan: S00 Thad Avenue New York, NY 10022 ♦1 212 957 7600 phone wenecohengessercom Counsel for the MDC may submit

rder to the MDC directing it to accept two hard drives from defense counsel that contain the non-Highly Confidential discovery in this case for Ms. Maxwell's use at the MDC. In an effort to facilitate Ms. Maxwell's review of the discovery, defense counsel have created a master set of two hard drives th

LED: 5/3/21 April 30, 2021 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Judge Nathan: S00

n-Highly Confidential discovery in this case for Ms. Maxwell's use at the MDC. In an effort to facilitate Ms.

countless hours to her review. Defense counsel would like to send these hard drives to Ms. Maxwell for her to use in the MDC. We were informed by the MDC Legal Department that they are only permitted to accept hard drives that are loaded and certified by the U.S. Attorney's Office. We have conferred with the governme

ited States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: USDC SONY DOCUMENT ELECTRONICALLY FILED DOC 0: DATE FILED: 1212120 The parties jointly submit this letter

Government, the defense's position is as follows: Warden Heriberto Tellez should appear before the Court to directly address concerns regarding Ms. Maxwell's conditions of confinement, which specifically target her. On October 29, 2020, the defense emailed a letter to Warden Tellez detailing the onerous

New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: US

the Court to directly address concerns regarding Ms. Maxwell's conditions of confinement, which specifically t

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

ited States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully submits this letter to provide an update regarding the defendant's conditions of

Government, the defense's position is as follows: Warden Heriberto Tellez should appear before the Court to directly address concerns regarding Ms. Maxwell's conditions of confinement, which specifically target her. On October 29, 2020, the defense emailed a letter to Warden Tellez detailing the onerous

the Court to directly address concerns regarding Ms. Maxwell's conditions of confinement, which specifically t

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