Epstein Secrets

Bobbi C. Sternheim, Esq. cc: via email Mark S. Cohen, Esq. Christian R. Everdell, Esq. Jeff Pagliuca

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

0330-AJN Document 116 Filed 01/15/21 Page 1 of 2 COHEN & GRESSER LLP sop Thud Avenue Nen York. NY 1002

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

0330-AJN Document 116 Filed 01/15/21 Page 1 of 2 COHEN & GRESSER LLP sop Thud Avenue Nen York. NY 1002

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

30-AJN Document 260 Filed Off1/00/21 Page 1 of 2 COHEN & GRESSER LLP BY ECF The Honorable Alison J. Na

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