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e Honorable Alison J. Nathan United States District Court Southern District of New York 40 Foley Square New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: This letter is written in response to your April 28, 2021, Order seeking the following information regarding
879-509, at the Metropolitan Detention Center in Brooklyn, New York (MDC Brooklyn) on April 24, 2021: 1. An inventory of the items seized from Ms. Maxwell in the incident that occurred on April 24, 2021 shall be provided by email to defense counsel only; 2. A representation indicating whether any of t
Square New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: Th
2021: 1. An inventory of the items seized from Ms. Maxwell in the incident that occurred on April 24, 2021
021, legal visit were any materials seized and retained by MDC Brooklyn staff. Those materials that defense counsel gave to Ms. Maxwell contrary to MDC Brooklyn's legal visit procedures were confiscated by staff and return Page 1 of 2 EFTA00066949 to defense counsel on April 25, 2021. In addition, none of M
. GHISLAINE MAXWELL, Appellant. On Appeal from the United States District Court for the Southern District of New York, 20-CR-330 (AJN) Appellant Ghislaine Maxwell's Renewed Motion for Pretrial Release Leah S. Saffian David Oscar Markus LAW OFFICES OF LEAH SAFFIAN *Counsel of Record ME- markuslaw.com EFTA00
I2-13) EFTA00089451 No. 21-770 & 21-58 In the ZiRita) *tates Court of Apprat5 for the *mufti Circuit UNITED STATES OF AMERICA, Appellee, v. GHISLAINE MAXWELL, Appellant. On Appeal from the United States District Court for the Southern District of New York, 20-CR-330 (AJN) Appellant Ghislaine Ma
for bond (see Ex. A, Order, April 27, 2021), it appeared concerned with the conditions of her confinement during oral argument and instructed Ms. Maxwell that "[t]o the extent Appellant seeks relief specific to her sleeping conditions, such request should be addressed to the District Court." (Id.).
uld be addressed to the District Court." (Id.). Ms. Maxwell did just that, explaining again to the trial judg
strict court concerning Ms. Maxwell's lawyers: "Those [privileged] materials that defense counsel 7 EFTA00089459 gave to Ms. Maxwell contrary to MDC Brooklyn's legal visit procedures were confiscated by staff..." Doc. 259. Ms. Maxwell's lawyers showed this was false and that they did not give anything to M
he Honorable Alison). Nathan United States District Court Southern District of New York 40 Foley Square New York, NY 10007 Re: United States v. Ghislaine Marvell, 20 Cr. 330 (AJN) Ghislaine Maxwell, Reg. No.02879.509 Dear Judge Nathan: This letter is written in response to Order granted on January 15, 2021,
(AJN) Ghislaine Maxwell, Reg. No.02879.509 Dear Judge Nathan: This letter is written in response to Order granted on January 15, 2021, concerning Ghislaine Maxwell, Reg. 02879-509., an inmate currently confined at the Metropolitan Detention Center (”MDC") in Brooklyn, New York. The MDC Brooklyn respect
, although the objection had been reiterated to the U.S. Attorney's Office numerous times. Defense counsel expressed various concerns regarding Ms. Maxwell's confinement limiting her access to discovery. However, Ms. Maxwell has received a significant amount of time to review her discovery. On November
ense counsel expressed various concerns regarding Ms. Maxwell's confinement limiting her access to discovery.
Despite defense counsel's claim that Ms. Maxwell's lacks sufficient time to fully review her discovery, her consistent use of Government laptop and MDC Brooklyn's discovery computers undercuts this claim. Moreover, Ms. Maxwell continues to have contact with her legal counsel five (5) days per week, three (3)
. GHISLAINE MAXWELL, Appellant. On Appeal from the United States District Court for the Southern District of New York, 20-CR-330 (AJN) Appellant Ghislaine Maxwell's Renewed Motion for Pretrial Release Leah S. Saffian LAW OFFICES OF LEAH SAFFIAN 15546 Meadowgate Road Encino, California 91436-3429 Tel: (858)4
21, 3102450, Paget of 14 No. 21-770 & 21-58 In the Malta *tates Court of Appeat5 for the *tomb Circuit UNITED STATES OF AMERICA, Appellee, v. GHISLAINE MAXWELL, Appellant. On Appeal from the United States District Court for the Southern District of New York, 20-CR-330 (AJN) Appellant Ghislaine Ma
for bond (see Ex. A, Order, April 27, 2021), it appeared concerned with the conditions of her confinement during oral argument and instructed Ms. Maxwell that "[t]o the extent Appellant seeks relief specific to her sleeping conditions, such request should be addressed to the District Court." (Id.).
uld be addressed to the District Court." (Id.). Ms. Maxwell did just that, explaining again to the trial judg
eged] materials that defense counsel 7 EFTA00096527 Case 21-58, Document 89-1, 05/17/2021, 3102450, Page10 of 14 gave to Ms. Maxwell contrary to MDC Brooklyn's legal visit procedures were confiscated by staff..." Doc. 259. Ms. Maxwell's lawyers showed this was false and that they did not give anything to M
Entities connected to both Ghislaine Maxwell and MDC Brooklyn's

Jeffrey Epstein
PERSONSouthern District
LOCATION
United States
LOCATION
George W. Bush
PERSON
Department of Justice
ORGANIZATIONthe Southern District
LOCATION
Alison J. Nathan
PERSONFederal Bureau of Prisons
ORGANIZATION
the United States District Court
ORGANIZATION
Metropolitan Correctional Center
ORGANIZATION
Foley Square
LOCATION
Tiffany Trump
PERSON
United States Department of Justice
ORGANIZATIONSpecial Housing Unit
ORGANIZATIONColleen McMahon
PERSONCourthouse
ORGANIZATIONDavid Oscar Markus
PERSON
Thurgood Marshall
PERSON
Orwell
PERSONR. App
PERSON