court filing: 20-cr-330 (AJN) Document 192-2 Filed 08/28/20 Page 40 of 45
Summary
The document argues that the proposed bail package for Ghislaine Maxwell is expansive and sufficient to warrant her release from custody, citing comparisons with other high-profile defendants and addressing government concerns about risk of flight.
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The document argues that the proposed bail package for Ghislaine Maxwell is expansive and sufficient...
The document argues that the proposed bail package for Ghislaine Maxwell is expansive and sufficient to warrant her release from custody, citing comparisons with other high-profile defendants and addressing government concerns about risk of flight.
Court Filing: 121362
The Government updates the court on Ghislaine Maxwell's conditions of confinement, stating she has extensive access to discovery materials and email communication with her attorneys. Maxwell is allowed to review discovery 13 hours a day, 7 days a week, using both an MDC-provided desktop and a Government-provided laptop. The document also addresses concerns about email deletion policies at the MDC.
Court Filing: 133
Ghislaine Maxwell's defense team files a motion to suppress evidence obtained from a government subpoena and to dismiss Counts Five and Six of the indictment, citing the Due Process Clause. The motion is supported by a memorandum of law and exhibits. The defense attorneys representing Maxwell are listed, along with their contact information.
Court Filing - Notice of Motion: 139
Ghislaine Maxwell's defense team files a motion to suppress evidence obtained from a government subpoena and to dismiss Counts Five and Six of the indictment, citing Fourth and Fifth Amendment violations. The motion is filed in the United States District Court for the Southern District of New York. The defense requests oral argument.
Court Filing - Exhibit: 148-5
This document is an exhibit filed in the case against Ghislaine Maxwell, listing the defense's requests for documents related to the Non-Prosecution Agreement negotiations between the government and Jeffrey Epstein, as well as communications between government agencies and attorneys for accusing witnesses. The requests cover a range of topics, including meetings between SDNY prosecutors and attorneys for accusing witnesses in 2016 and 2018.
Court Filing: 196
The document is a letter from the US Government to Judge Alison J. Nathan updating the court on Ghislaine Maxwell's conditions of confinement at the MDC, detailing her access to discovery materials, communication with attorneys, and search procedures. The Government reports that Maxwell has extensive access to discovery materials and her attorneys, and that the MDC has taken steps to accommodate her needs while maintaining institutional security.
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