EFTA00018572.pdf

"On behalf of our client, Ghislaine Maxwell, we respectfully submit this letter motion"

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

"Dear Judge Nathan: ... Re: United States v. Ghislaine Maxwell"

"directing the Bureau of Prisons ("BOP") to release Ms. Maxwell into the general population... while she is detained"

"Case 1:20-cr-00330-AJN ... Ms. Maxwell can receive a fair trial"

"The Honorable Alison J. Nathan ... Case 1:20-cr-00330-AJN"

"Since arriving at the MDC over a month ago, on July 6, 2020, Ms. Maxwell has been held under uniquely onerous conditions."

"On July 6, 2019, Mr. Epstein was arrested and detained at the Metropolitan Correctional Center (MCC)"

"Mr. Epstein was arrested and detained at the Metropolitan Correctional Center (MCC) on sex trafficking charges"

"Respectfully submitted, /s/ Christian R. Everdell Mark S. Cohen"

"Respectfully submitted, /s/ Christian R. Everdell"

"the government indicted the two correctional officers who were assigned to the SHU at the time of Mr. Epstein's death"

"identities of Victims 1-3, the defense is losing crucial time to conduct a meaningful investigation"

"the alleged misconduct took place... in multiple locations—namely, New York, Florida, New Mexico, and the United Kingdom"

"the alleged misconduct took place... in multiple locations—namely, New York, Florida, New Mexico, and the United Kingdom"

"the alleged misconduct took place... in multiple locations—namely, New York, Florida, New Mexico, and the United Kingdom"

"Defense counsel understands that the BOP has proposed (but not yet implemented) a procedure that would permit Ms. Maxwell to use a computer on her flo"

"the central figure, Jeffrey Epstein, is alleged to have engaged in misconduct with dozens, if not hundreds, of alleged victims. The defense should not"

"Ms. Maxwell and defense counsel can meaningfully investigate the alleged conduct, which is now over 25 years old... identities of the three alleged vi"

"It has become apparent that the GOP's treatment of Ms. Maxwell is a reaction to the circumstances surrounding the pretrial detention and death of Mr. "