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This legal document is a letter dated July 7, 2020, from the U.S. Attorney for the Southern District of New York to Judge Alison J. Nathan regarding the criminal case against Ghislaine Maxwell. The prosecution proposes a briefing schedule for Maxwell's detention hearing following her arrest on July 2, 2020, and renews its request to exclude time under the Speedy Trial Act. The letter confirms the parties are available for a remote hearing on July 14, 2020.
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This document is a letter from the U.S. Attorney to Judge Alison J. Nathan providing an update on Ghislaine Maxwell's confinement conditions at the MDC. The Government asserts that Maxwell receives exceptional access to discovery materials (13 hours/day, 7 days/week) via both a laptop and desktop. A footnote addresses complaints regarding missing emails, stating that an investigation revealed Maxwell deleted or archived them herself, with no evidence of MDC staff misconduct.
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This legal document is a letter from the U.S. Attorney for the Southern District of New York to Judge Alison J. Nathan, dated February 4, 2021. The letter provides an update on the conditions of confinement for the defendant, Ghislaine Maxwell, at the Metropolitan Detention Center (MDC). The Government reports that Maxwell has more time to review discovery materials than any other inmate (13 hours daily via computer) and has regular, private communication with her attorneys through video and phone calls, despite the suspension of in-person visits due to COVID-19.
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A letter from the U.S. Attorney's Office to Judge Alison J. Nathan dated February 1, 2021, regarding the conditions of Ghislaine Maxwell's confinement at the MDC. The Government addresses a dispute over Maxwell's access to a laptop for reviewing over two million pages of discovery materials on weekends and holidays. While the Government does not object to the access, they defer to MDC management protocols, noting that Maxwell already receives more review time (13 hours/day, 7 days/week) than any other inmate.
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This letter, dated November 23, 2020, is from the U.S. Attorney for the Southern District of New York to Judge Alison J. Nathan. It provides an update on the confinement conditions of defendant Ghislaine Maxwell at the Metropolitan Detention Center (MDC). The letter details that Maxwell was placed in quarantine after a potential COVID-19 exposure from a staff member, outlines the quarantine protocols, and confirms that she has been provided with a laptop to review discovery materials and can still make private legal calls.
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This document is a letter from the U.S. Department of Justice to Judge Alison J. Nathan dated March 9, 2021, opposing Ghislaine Maxwell's third motion for release on bail. The Government argues that the Court lacks jurisdiction due to a pending appeal with the Second Circuit and reiterates that Maxwell poses an extreme flight risk that no conditions can mitigate. The letter references previous denials of bail on July 14, 2020, and December 28, 2020.
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This document is a letter dated July 25, 2019, from the U.S. Attorney's Office for the Southern District of New York (specifically Assistant US Attorney Alison Moe) to Judge Richard M. Berman. The prosecution requests the Court to endorse a proposed protective order in the case of United States v. Jeffrey Epstein, noting that defense counsel (Martin Weinberg and Reid Weingarten) have consented to the order.
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This legal document is a letter dated July 15, 2019, from the U.S. Attorney for the Southern District of New York to Judge Richard M. Berman regarding the case *United States v. Jeffrey Epstein*. The prosecution requests the exclusion of speedy trial time for the period of July 15-18, 2019, noting that Epstein's defense counsel consents to the request. The document is endorsed by Judge Berman, who granted the application on July 16, 2019.
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This legal document is a letter dated July 15, 2019, from the U.S. Attorney for the Southern District of New York, Geoffrey S. Berman, to Judge Richard M. Berman. The letter formally requests the exclusion of speedy trial time in the criminal case against Jeffrey Epstein for the period between July 15 and July 18, 2019. The filing notes that Epstein's defense counsel, Martin Weinberg and Reid Weingarten, have been consulted and consent to the request.
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This legal document is a letter from the U.S. Attorney for the Southern District of New York to Judge Richard M. Berman, dated July 12, 2019, arguing against Jeffrey Epstein's motion for pretrial release. The government portrays Epstein as an unrepentant serial sexual predator who poses a significant flight risk due to his vast wealth and the likelihood of a life sentence. The letter cites substantial evidence, including photographs found in his mansion and a history of witness manipulation, to support its request for continued detention.
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A letter from the U.S. Attorney's Office (SDNY) to Judge Richard Berman regarding the case United States v. Jeffrey Epstein. The Government requests an extension of the deadline to respond to Epstein's bail motion because the defense has failed to provide necessary financial disclosures on time. The document is stamped as filed on July 12, 2019.
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This legal document is a letter from the U.S. Attorney for the Southern District of New York to Judge Alison J. Nathan regarding the case of Ghislaine Maxwell. The government states it does not object to Maxwell's request for weekend laptop access to review discovery materials but ultimately defers to the Metropolitan Detention Center's (MDC) policies. The letter emphasizes that Maxwell has already been provided with extensive access, including a dedicated laptop and desktop computer, for more hours than any other inmate.
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This legal document is a letter from the U.S. Attorney for the Southern District of New York to Judge Alison J. Nathan, dated February 1, 2021, regarding the case against Ghislaine Maxwell. The government responds to Maxwell's request for expanded laptop access to review discovery materials on weekends, stating it has no objection but ultimately defers to the Metropolitan Detention Center's (MDC) policies. The letter details the extensive access Maxwell has already been granted, including a dedicated laptop and desktop computer, arguing she has ample opportunity to review the evidence.
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This is a letter from the U.S. Attorney for the Southern District of New York to Judge Alison J. Nathan regarding the case of United States v. Ghislaine Maxwell. Dated January 28, 2021, the letter responds to a court order about proposed redactions to the defendant's pre-trial motions. The Government states its agreement with the proposed redactions, arguing they are necessary to protect the integrity of an ongoing investigation, maintain grand jury secrecy, and protect the privacy of victim-witnesses.
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A legal letter dated December 30, 2020, from the U.S. Attorney's Office (SDNY) to Judge Alison J. Nathan regarding the case United States v. Ghislaine Maxwell. The letter confirms that neither the prosecution nor the defense proposes any redactions to the Court's December 28, 2020 Opinion and Order denying Maxwell's renewed bail motion. The document is signed by Assistant US Attorneys Maurene Comey, Alison Moe, and Lara Pomerantz.
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This document is a confidential letter dated November 17, 2020, addressed to Judge Alison J. Nathan, advocating for Ghislaine Maxwell's release on bail. The anonymous author attests to Maxwell's good character, offers a $2,000 bond, and describes a long-standing relationship with Maxwell and her family, arguing against flight risk and highlighting severe confinement conditions.
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This document is a letter dated November 30, 2020, addressed to Judge Alison J. Nathan, providing a character reference for Ghislaine. The author, whose name is redacted, describes a lifelong friendship with Ghislaine, highlighting her positive qualities, shared interests, and dedication to the non-profit TerraMar Project for ocean protection.
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This legal document is a letter dated November 23, 2020, from the U.S. Attorney for the Southern District of New York to Judge Alison J. Nathan. The letter provides an update on the confinement conditions of defendant Ghislaine Maxwell at the Metropolitan Detention Center (MDC), specifically that she was placed in quarantine after a staff member tested positive for COVID-19. The letter details that Maxwell tested negative, outlines the protocols for her quarantine including access to legal calls and discovery materials, and confirms she is being monitored by medical staff.
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This document is a letter from the U.S. Department of Justice to Judge Alison J. Nathan requesting a two-week extension (until Nov 23, 2020) to produce electronic discovery in the case against Ghislaine Maxwell. The delay is attributed to an outside vendor needing more time to process data from electronic devices seized by the FBI from Jeffrey Epstein's residences in NY and the Virgin Islands in 2019. The letter details the history of the data seizure, privilege reviews requested by Epstein's estate, and mentions that over 350,000 pages of discovery have already been produced.
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This is a letter from the U.S. Department of Justice to Judge Alison J. Nathan regarding the case *United States v. Ghislaine Maxwell*. The Government requests to delay the disclosure of certain photographs and documents related to Jeffrey Epstein's victims until eight weeks before trial to protect an ongoing investigation. The Government argues these materials concern abuse occurring after the indictment period (post-1997) and are not exculpatory regarding the charges against Maxwell for the 1994-1997 period.
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This legal document is a letter dated October 6, 2020, from the U.S. Attorney for the Southern District of New York to Judge Alison J. Nathan. The prosecution requests permission to delay the disclosure of sensitive evidence—photographs and documents of Jeffrey Epstein's sexual abuse victims—to Ghislaine Maxwell's defense team until eight weeks before trial. The government argues this is necessary to protect an ongoing investigation and sensitive victim information, while noting the defense objects to this request.
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This is a court order from the Southern District of New York, dated November 19, 2019, signed by District Judge Analisa Torres. The order schedules an initial conference for defendants Tova Noel and Michael Thomas (the guards on duty the night of Jeffrey Epstein's death) for November 25, 2019, at the United States Courthouse in New York.
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This is a letter from the U.S. Department of Justice (SDNY) to Judge Alison J. Nathan regarding the case United States v. Ghislaine Maxwell. The Government requests that exhibits attached to a Defense Letter from August 17, 2020, be filed under seal and that the letter itself be redacted because the materials pertain to an ongoing grand jury investigation. The Government cites Federal Rule of Criminal Procedure 6(e)(6) and a Protective Order to support the confidentiality of these documents.
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A letter from the U.S. Department of Justice to Judge Alison J. Nathan opposing Ghislaine Maxwell's request to use discovery materials from her criminal case in unrelated civil litigation. The Government notes it has produced over 165,000 pages of evidence and argues that the materials in question are appropriately designated as confidential because they relate to an ongoing criminal investigation and grand jury proceedings.
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This document is a letter dated July 27, 2020, from Ghislaine Maxwell's defense attorneys (Cohen & Gresser LLP) to Judge Alison J. Nathan regarding the case United States v. Ghislaine Maxwell. The defense is requesting the entry of a protective order regarding discovery materials but outlines two remaining disputes with the government: 1) restrictions on government witnesses posting discovery materials to the internet, and 2) the defense's ability to publicly identify alleged victims who have already spoken on the public record.
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