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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

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

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

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

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

From: To: Cc: (USANYS)" a m i l m YS "-IMMIIMM IM (USANYS)" Subject: FW: Activity in Case 1:20-cr-00330-AJN USA v. Maxwell Order Date: Tue, 08 Dec 2020 17:45:50 +0000 Attachments: 2020.12.08_AJN_Order_re_MDC.pdf Best, Southern District of New York 1 St. Andrew's Plaz

02 PM EST and filed on 12/8/2020 Case Name: USA v. Maxwell Case Number: I :20-cr-00330-AJN Filer: Document Number:92 Docket Text: ORDER as to Ghislaine Maxwell: On December 4, 2020, the Court received a letter from MDC legal counsel responding to the concerns that the Defendant raised in her November 24, 20

r: Document Number:92 Docket Text: ORDER as to Ghislaine Maxwell: On December 4, 2020, the Court received

ailing any material changes to the conditions of Ms. Maxwell's confinement, with particular emphasis on her ac

so Dkt. No. 78. The Defendant responded to the MDC legal counsel's letter on December 7, 2020, reiterating her request that the Court summon Warden Heriberto Tellez to personally respond to questions from the Court regarding the Defendant's conditions of confinement. See Dkt. No. 91. Having carefully reviewed th

From: To: Subject Re: FW: Activity in Case 1:20-cr-00330-AJN USA v. Maxwell Order Date: Wed, 09 Dec 2020 12:28:16 +0000 Thanks Good If er r, 12/8/2020 12:45 PM >> > Best, Southern District of New York l St. Andrew's Pl

02 PM EST and filed on 12/8/2020 Case Name: USA v. Maxwell Case Number: 1:20-cr-00330-AJN Filer: Document Number: 92 Docket Text: ORDER as to Ghislaine Maxwell: On December 4, 2020, the Court received a letter from MDC legal counsel responding to the concerns that the Defendant raised in her November 24, 20

: Document Number: 92 Docket Text: ORDER as to Ghislaine Maxwell: On December 4, 2020, the Court received

ailing any material changes to the conditions of Ms. Maxwell's confinement, with particular emphasis on her ac

so Dkt. No. 78. The Defendant responded to the MDC legal counsel's letter on December 7, 2020, reiterating her request that the Court summon Warden Heriberto Tellez to personally respond to questions from the Court regarding the Defendant's conditions of confinement. See Dkt. No. 91. Having carefully reviewed th

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

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

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

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

1:20-cr-00330-AJN Document 92 Filed 12/08/20 Page 1 of 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. USDC SONY DOCUMENT ELECTRONICALLY FILED DOC 0: DATE FILED: 12/8/20 20-CR-330 (MN) ORDER ALISON J. NATHAN, District Judge: On De

lly provided in Dkt. No. 49, the Government shall continue to submit written status updates detailing any material changes to the conditions of Ms. Maxwell's confinement, with particular emphasis on her access to legal materials, including legal mail and email, and her ability to communicate with defens

TRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. USDC SONY DOCUMENT ELECTR

lso Dkt. No. 78. The Defendant responded to the MDC legal counsel's letter on December 7, 2020, reiterating her request that the Court summon Warden Heriberto Tellez to personally respond to questions from the Court regarding the Defendant's conditions of confinement. See Dkt. No. 91. Having carefully reviewed t

1:20-cr-00330-AJN Document 92 Filed 12/08/20 Page 1 of 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. L'SDC SDNY DOCUMENT ELECTRONICALLY FILED DOC 0: DATE FILED: 12/8/20 20-CR-330 (MN) ORDER ALISON J. NATHAN, District Judge: On D

lly provided in Dkt. No. 49, the Government shall continue to submit written status updates detailing any material changes to the conditions of Ms. Maxwell's confinement, with particular emphasis on her access to legal materials, including legal mail and email, and her ability to communicate with defens

TRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. L'SDC SDNY DOCUMENT ELECT

lso Dkt. No. 78. The Defendant responded to the MDC legal counsel's letter on December 7, 2020, reiterating her request that the Court summon Warden Heriberto Tellez to personally respond to questions from the Court regarding the Defendant's conditions of confinement. See Dkt. No. 91. Having carefully reviewed t

1:20-cr-00330-AJN Document 92 Filed 12/08/20 Page 1 of 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. L'SDC SDNY DOCUMENT ELECTRONICALLY FILED DOC 0: DATE FILED: 12/8/20 20-CR-330 (MN) ORDER ALISON J. NATHAN, District Judge: On D

lly provided in Dkt. No. 49, the Government shall continue to submit written status updates detailing any material changes to the conditions of Ms. Maxwell's confinement, with particular emphasis on her access to legal materials, including legal mail and email, and her ability to communicate with defens

TRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. L'SDC SDNY DOCUMENT ELECT

lso Dkt. No. 78. The Defendant responded to the MDC legal counsel's letter on December 7, 2020, reiterating her request that the Court summon Warden Heriberto Tellez to personally respond to questions from the Court regarding the Defendant's conditions of confinement. See Dkt. No. 91. Having carefully reviewed t

NY 10007 Dear Judge Nathan: 33 West 19th Street - 4th Floor New York, New York 10011 [email protected] November 24, 2020 Re: United States v. Ghislaine Maxwell 20 Cr. 330 (AJN) USDC SDNY DOCUMENT ELECTRONICALLY FILED DOCO: DATE FILED: 11/24/20 As counsel for Ghislaine Maxwell, I write in response to t

LED: 11/24/20 As counsel for Ghislaine Maxwell, I write in response to the government's letter, dated November 23, 2020 (see Dkt 74), reporting Ms. Maxwell's conditions of detention and confirming that she is currently in quarantine due to contact with a staff member, assigned to her isolation pod, who

mlaw.com November 24, 2020 Re: United States v. Ghislaine Maxwell 20 Cr. 330 (AJN) USDC SDNY DOCUMENT E

dated November 23, 2020 (see Dkt 74), reporting Ms. Maxwell's conditions of detention and confirming that sh

the disparate treatment of Ms. Maxwell. Rather than receive second-hand information from counsel, the defense requests that the Court summon Warden Heriberto Tellez to report directly to the Court and counsel on Ms. Maxwell's conditions of detention. Your consideration is greatly appreciated. Very truly yours,