Epstein Secrets

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 submit any objection to the Defendant's request by May 4, 2021. S

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

United States District Judge 2 EFTA00072493 Case 1:20-cr-00330-AJN Document 116 Filed 01/15/21 Page 1 of 2 COHEN & GRESSER LLP sop Thud Avenue Nen York. NY 10022 Christian R. Everdell +1 (21.2) 957-76(10 ccvcracligcolungresscr.com BY ECF The Honorable Alison J. Nathan United States District Cou

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

United States District Judge 2 EFTA00072479 Case 1:20-cr-00330-AJN Document 116 Filed 01/15/21 Page 1 of 2 COHEN & GRESSER LLP sop Thud Avenue Nen York. NY 10022 Christian R. Everdell +1 (21.2) 957-76(10 ccvcracligcolungresscr.com BY ECF The Honorable Alison J. Nathan United States District Cou

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