U.S. DEPARTMENT OF JUSTICE
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U.S. DEPARTMENT OF JUSTICE Federal Bureau of Prisons Metropolitan Detention Center 80 29" Street Bros*, New York 11232 April 29, 2021 BY ECF The Honorable Alison J. Nathan United States District Court Southern District of New York 40 Foley Square New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: This letter is written in response to your April 28, 2021, Order seeking the following information regarding an alleged incident involving Ghislaine Maxwell, Register No. 02879-509, at the Metropolitan Detention Center in Brooklyn, New York (MDC Brooklyn) on April 24, 2021: 1. An inventory of the items seized from Ms. Maxwell in the incident that occurred on April 24, 2021 shall be provided by email to defense counsel only; 2. A representation indicating whether any of the seized materials were duplicated in any fashion and what investigation was undertaken in order to determine this information; a. A representation indicating
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EFTA DisclosureRelated Documents (6)
Case 1:20-cr-00330-AJN Document 74 Filed 11/23/20 Page 1 of 2
Case 1:20-cr-00330-AJN Document 74 Filed 11/23/20 Page 1 of 2 U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 November 23, 2020 BY ECF The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully submits this letter to provide an update regarding the defendant's conditions of confinement at the Metropolitan Detention Center ("MDC") pursuant to the Court's Order dated August 25, 2020. (Dkt. No. 49). Over the past three months, the Government has had multiple conversations with MDC legal counsel regarding the defendant's conditions of confinement. This update is based on information provided to the Government by MDC legal during those conversations. Last week,
Case 1:20-cr-00330-AJN Document 78 Filed 12/01/20 Page 1 of 2
Case 1:20-cr-00330-AJN Document 78 Filed 12/01/20 Page 1 of 2 U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Malin Building One Saint Andrew's Plaza New York. New York 10007 December 1, 2020 BY ECF The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The parties jointly submit this letter in response to the Court's November 24, 2020 order directing the parties to meet and confer regarding the defendant's request that the warden of the Metropolitan Detention Center ("MDC") report directly to the Court and counsel on the defendant's conditions of detention. (Dkt. No. 76). Over the past week, the Government has spoken with MDC legal counsel regarding the defendant's conditions of confinement and has tried to gather additional information regard
From: '
From: ' y• < To: BOBBI Cc:' Subject: RE: Ghislaine Maxwell 02879-509 Date: Mon, 16 Nov 2020 18:06:58 +0000 (USANYS)" Bobbi, Thank you for including me on this email. I understand from my conversation with MDC legal counsel today that MDC staff is continuing to monitor temperatures throughout the facility, including in the area where Ms. Maxwell is housed. My understanding is that the temperature where Ms. Maxwell is housed remains within the limits prescribed by BOP policy and that the MDC does not expect this week's activities to affect the temperature in Ms. Maxwell's cell. That said, they will continue to monitor the temperature and take appropriate action if it falls below prescribed limits. As has previously been conveyed via letter from the Government to defense counsel dated October 8, 2020, the MDC's assessment continues to be that Ms. Maxwell's current cell is the most appropriate placement for Ms. Maxwell both for her safety and the security of the institution.
January 25, 2021
January 25, 2021 U.S. DEPARTMENT OF JUSTICE Federal Bureau of Prisons Metropolitan Detention Center 80 291: Street Brooklyn. New York 11232 BY ECF The Honorable Alison). Nathan United States District Court Southern District of New York 40 Foley Square New York, NY 10007 Re: United States v. Ghislaine Marvell, 20 Cr. 330 (AJN) Ghislaine Maxwell, Reg. No.02879.509 Dear Judge Nathan: This letter is written in response to Order granted on January 15, 2021, concerning Ghislaine Maxwell, Reg. 02879-509., an inmate currently confined at the Metropolitan Detention Center (”MDC") in Brooklyn, New York. The MDC Brooklyn respectfully requests that Your Honor vacate the Order given MDC Brooklyn was not given the opportunity to object to defense counsel's claims, although the objection had been reiterated to the U.S. Attorney's Office numerous times. Defense counsel expressed various concerns regarding Ms. Maxwell's confinement limiting her access to discovery. However, Ms. Ma
U.S. Department of Justice
U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Motto Building One Saint Andrew's Plaza New York. New York 10007 July 28, 2020 VIA ECF The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully submits this letter with respect to the protective order to be entered in the above-captioned case, and to respond to the defendant's letter and submission of July 27, 2020 (the "Defendant Letter" or "Def. Ltr.") (Dkt. 29). The Government and defense counsel have conferred regarding a protective order several times via telephone and email between July 9, 2020, and today, including as recently as this morning. The Government and defense counsel have come to an agreement on much of the proposed protective order. However, the parties
UNITED STATES DISTRICT COURT
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA S 120 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x THE GOVERNMENT'S OMNIBUS MEMORANDUM IN OPPOSITION TO THE DEFENDANT'S PRE-TRIAL MOTIONS AUDREY STRAUSS United States Attorney Southern District of New York Attorney for the United States of America Assistant United States Attorneys - Of Counsel - EFTA00039421 TABLE OF CONTENTS PRELIMINARY STATEMENT 1 BACKGROUND 2 ARGUMENT 3 I. Jeffrey Epstein's Non-Prosecution Agreement Is Irrelevant to This Case 3 A. The NPA Does Not Bind the Southern District of New York 4 1. The Text of the Agreement Does Not Contain a Promise to Bind Other Districts 5 2. The Defendant Has Offered No Evidence That the NPA Binds Other Districts 9 B. The NPA Does Not Immunize Maxwell from Prosecution 15 1. The NPA Is Limited to Particular Crimes Between 2001 and 2007 15 2. The NPA Does Not Confer Enforceable Rights on Maxwell 17 C. The Defendant
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