EFTA00013225.pdf

"United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)"

"incomplete and inadequate production of discovery to Ms. Maxwell in the MDC... we demand that the government find an immediate solution"

"United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)"

"United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)"

"production of discovery to Ms. Maxwell in the MDC"

"We write to address three issues."

"Ms. Maxwell's conditions of confinement are extraordinarily onerous and unlike those of any other inmate at the MDC"

"Ms. Maxwell is forced to sleep and spend half of her time in a confined space ominously referred to as the isolation cell"

"Ms. Maxwell and Defense Counsel Request Access to All Documents Designated as Highly Confidential"

"Ms. Maxwell's conditions of confinement are extraordinarily onerous and unlike those of any other inmate at the MDC (or in BOP custody, to our knowled"

"According to the Protective Order in this case, Ms. Maxwell may only review the documents marked by the government as Highly Confidential in the prese"

"Ms. Maxwell has been at the MDC, she has met with four separate wardens and interim wardens"

"on August 13, 2020, her counsel placed an Amazon order ... Sincerely, /s/ Christian Everdell"

"shortly after she arrived at the MDC. ... provide written status updates every 90 days detailing any material changes to conditions of Ms. Maxwell's c"

"BOP personnel broke in a search of her cell shortly after she arrived at the MDC. ... the government and the BOP are not providing adequate conditions"

"Ms. Maxwell has also not received shipments of approved items from Amazon. ... Both deliveries were rejected as undeliverable without reason. ... none"

"she nevertheless ordered the government to provide written status updates every 90 days detailing any material changes to conditions of Ms. Maxwell's "

"We therefore ask the government to speak to the warden about ensuring that Ms. Maxwell's personal mail is delivered in a timely fashion"

"on August 13, 2020, her counsel placed an Amazon order for a package of five BOP-approved flexible pens and eight BOP-approved legal pads."

"Ms. Maxwell has been provided hard drives containing a substantial number of unreadable files and therefore still cannot review the entire discovery p"

"replace the ones that BOP personnel broke in a search of her cell shortly after she arrived at the MDC."

"Ms. Maxwell's friends and family members have mailed her numerous letters since she arrived at the MDC."

"We request that the government intercede directly with the BOP to improve these conditions"

"we now ask the government to intercede with the BOP to make the following improvements"

"She is not being fed a sufficient amount of food and is losing a great deal of weight ... These measures are akin to punishment, which is inappropriat"

"Ms. Maxwell is also subjected to a level of surveillance that is intrusive, aggressive, constant, unnecessary and unjustifiable"

"Ms. Maxwell had her mouth searched by prison guards who put their hands inside her mouth... she is woken up by flashing lights, loud discussions among"

"the government's August 5'h production... did not receive the hard drive with the government's third and final production"