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Bobbi C. Sternheim, Esq. cc: via email Mark S. Cohen, Esq. Christian R. Everdell, Esq. Jeff Pagliuca
e her opportunity to confer with counsel and prepare her defense for trial and are detrimental to her physical health and psychological well-being: De Facto Solitary Confinement: Ms. Maxwell is the sole inmate in a housing unit. By this Court's order she is permitted out of her approximately 9-by-7-foot isolation cell from 7
N SUPPORT OF HER RENEWED MOTION FOR BAIL Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP Jeff
MDC warden, dated October 29, 2020, which details the most serious and extraordinarily restrictive conditions of confinement. 12 These include: ■ De Facto Solitary Confinement ■ Excessive Surveillance ■ Excessive Scanning and Strip Searching ■ Deprivation of Food ■ Deprivation of Sleep ■ Deprivation of Communicati
N SUPPORT OF HER RENEWED MOTION FOR BAIL Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP Jeff
MDC warden, dated October 29, 2020, which details the most serious and extraordinarily restrictive conditions of confinement. 12 These include: ■ De Facto Solitary Confinement ■ Excessive Surveillance ■ Excessive Scanning and Strip Searching ■ Deprivation of Food ■ Deprivation of Sleep ■ Deprivation of Communicati
N SUPPORT OF HER RENEWED MOTION FOR BAIL Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP New
MDC warden, dated October 29, 2020, which details the most serious and extraordinarily restrictive conditions of confinement. 12 These include: ■ De Facto Solitary Confinement ■ Excessive Surveillance ■ Excessive Scanning and Strip Searching ■ Deprivation of Food ■ Deprivation of Sleep ■ Deprivation of Communicati
Entities connected to both Michael Cohen and De Facto Solitary Confinement

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSONJeffrey Pagliuca
PERSON
United States
LOCATION
George W. Bush
PERSONCohen & Gresser LLP
ORGANIZATION
Stephen Hawking
PERSONMark S. Cohen
PERSONthe Southern District
LOCATION
Harvey Weinstein
PERSON
Vicky Ward
PERSONSecond Circuit
ORGANIZATIONR. Everdell
PERSON
New Hampshire
LOCATION
Denmark
LOCATIONMORGAN & FOREMAN
ORGANIZATIONBoustani
PERSONKarni
PERSON
Bill Cosby
PERSONRaniere
PERSON