Proposed letter and declarations from associate wardens at MDC and MCC for review. GC and PC chiefs have signed off. Urgency due to MCC/MDC contacts leaving early before 1/1/30 and need to finalize declarations ASAP.
This document is an email chain from late December 2020 discussing disparities in counsel and discovery access for Ghislaine Maxwell (detained at MDC) and Justin Rivera (detained at MCC). Judge Engelmayer requested a declaration from the Bureau of Prisons to explain why Maxwell's accommodations were 'strikingly different and far superior' to Rivera's, citing differences in case complexity, housing situations, and inmate populations at the respective facilities. The emails detail the efforts to draft this declaration and address specific questions and concerns regarding the document's content and timeline.
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