Epstein Secrets

om: "-(USANYS)" To: " SANYS Cc: (USANYS)" (USAN YS)" SANYS USANYS)" (USANYS) 1" Subject: RE: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera Date: Wed, 30 Dec 2020 21:23:34 +0000 la who is the Associate Warden at the MCC. There's a possibility that there will be a very

den at the MCC. There's a possibility that there will be a very short declaration from someone at the MDC to discuss the specific accommodations for Maxwell. I am working through that with From: (USANYS) Sent: Wednesday, December 30, 2020 2:45 PM To: (USANYS) (USANYS) (USANYS)<Ma; (USANYS) ) Cc:

: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera Date: Wed, 30 Dec 2020

are in the process of finalizing our response to the Maxwell/Rivera issue. We intend to explain that the disc

o discuss this further. In the meantime, we are working with to identify the appropriate declarant and draft an explanation for the Court. Best, Bhaskaran Assistant United States Attorney United States Attorney's Office for the Southern District of New York One Saint Andrew's Plaza New York NY 10007

From: ' (USANYS)" To: (USANYS)" Subject: FW: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera Date: Thu, 31 Dec 2020 19:03:11 +0000 Attachments: 2020.12.31_ Decl_re_Maxwell_(v.2).docx; 2020.12.31 on_Rivera_and_Maxwell_d

den at the MCC. There's a possibility that there will be a very short declaration from someone at the MDC to discuss the specific accommodations for Maxwell. I am working through that with From: (USANYS) Sent: Wednesday, December 30, 2020 2:45 PM To: (USANYS) ca; (USANYS) (USANYS) (USANYS) ) < <

: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera Date: Thu, 31 Dec 2020

are in the process of finalizing our response to the Maxwell/Rivera issue. We intend to explain that the disc

o discuss this further. In the meantime, we are working with to identify the appropriate declarant and draft an explanation for the Court. Best, Bhaskaran Assistant United States Attorney United States Attorney's Office for the Southern District of New York One Saint Andrew's Plaza New York NY 10007

From: ' To: ' (USANYS)" Subject: RE: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera Date: Thu, 31 Dec 2020 16:57:54 +0000 Thanks . Would it be possible to clarify that although Maxwell has access to a social phon

covery Access for Ghislaine Maxwell and Justin Rivera Date: Thu, 31 Dec 2020 16:57:54 +0000 Thanks . Would it be possible to clarify that although Maxwell has access to a social phone, she has the same limited number of minutes for social calls per month as all other inmates? I just don't want to give

: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera Date: Thu, 31 Dec 2020

anks very much, M, and I have reviewed, and from the Maxwell team's perspective, these documents are accurate

USANYS) 1 <ME :z.; (USANYS) < Subject: Re: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera Thanks to you all! Bhaskaran (USANYS) cM > EFTA00086756 Assistant United States Attorney Sent from my iPhone On Dec 30, 2020, at 10:09 PM, wrote: Thanks very much, M, a

hings, but they shouldn't impact the substance of the Maxwell discussion. There is also a chance that there's

From: ' r To: ' " •cl (USANYS)" Subject: FW: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera Date: Thu, 31 Dec 2020 00:38:23 +0000 r Attachments: 2020.12.31 tt S r on_Rivera_and_Maxwell_discovery_and_counsel_access_(v.2

s the latest draft of our letter and declaration on this issue. We are still confirming a few things, but they shouldn't impact the substance of the Maxwell discussion. There is also a chance that there's a separate declaration from the MDC; if there is, it should contain the same substance re: Maxwell

: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera Date: Thu, 31 Dec 2020

o discuss this further. In the meantime, we are working with to identify the appropriate declarant and draft an explanation for the Court. Best, Bhaskaran Assistant United States Attorney United States Attorney's Office for the Southern District of New York One Saint Andrew's Plaza New York NY 10007

From: To: Cc: (USANYS)" r Subject: Re: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera Date: Thu, 31 Dec 2020 03:06:18 +0000 No issues from me. Thanks. Sent from my iPhone On Dec 30, 2020, at 9:38 PM, This seems f

s the latest draft of our letter and declaration on this issue. We are still confirming a few things, but they shouldn't impact the substance of the Maxwell discussion. There is also a chance that there's a separate declaration from the MDC; if there is, it should contain the same substance re: Maxwell

: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera Date: Thu, 31 Dec 2020

hings, but they shouldn't impact the substance of the Maxwell discussion. There is also a chance that there's

o discuss this further. In the meantime, we are working with to identify the appropriate declarant and draft an explanation for the Court. Best, Bhaskaran Assistant United States Attorney United States Attorney's Office for the Southern District of New York One Saint Andrew's Plaza New York NY moor

From: (USANYS)" To: ' (USANYS)" czi Subject: FW: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera Date: Thu, 31 Dec 2020 15:33:39 +0000 Attachments: 2020.12.31 Best Decl _ re_ Rivera and_Maxwell_(v.3).docx; _ _ 2020.12.3I_Le

s the latest draft of our letter and declaration on this issue. We are still confirming a few things, but they shouldn't impact the substance of the Maxwell discussion. There is also a chance that there's a separate declaration from the MDC; if there is, it should contain the same substance re: Maxwell

: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera Date: Thu, 31 Dec 2020

hings, but they shouldn't impact the substance of the Maxwell discussion. There is also a chance that there's

o discuss this further. In the meantime, we are working with to identify the appropriate declarant and draft an explanation for the Court. Best, Bhaskaran Assistant United States Attorney United States Attorney's Office for the Southern District of New York One Saint Andrew's Plaza New York NY 10007

From: (USANYS)" To: ' (USANYS)" Bee: (USANYS)" Subject: Re: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera Date: Thu, 31 Dec 2020 19:07:26 +0000 I'm restarting outlook. Will send as soon as it reboots. On Dec 31, 2020, at 2:06 PM, Oh

: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera Date: Thu, 31 Dec 2020

den at the MCC. There's a possibility that there will be a very short declaration from someone at the MDC to discuss the specific accommodations for Maxwell. I am working through that with From: (USANYS) <N > Sent: Wednesday, December 30, 2020 2:45 PM To: (USANYS) (USANYS) (USANYS) < (USANYS) >;

are in the process of finalizing our response to the Maxwell/Rivera issue. We intend to explain that the disc

o discuss this further. In the meantime, we are working with to identify the appropriate declarant and draft an explanation for the Court. Best, Bhaskaran Assistant United States Attorney United States Attorney's Office for the Southern District of New York One Saint Andrew's Plaza New York NY z0007