Metropolitan Detention Center (MDC)
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20-3061_Documents.pdf
This document is the complete appellate record for case 20-3061, an interlocutory appeal by Ghislaine Maxwell against the United States. Maxwell appealed a District Court order denying her motion to modify a protective order, seeking permission to share confidential criminal discovery materials under seal with the judge in a related civil case (Giuffre v. Maxwell) to challenge the government's acquisition of evidence. The Second Circuit Court of Appeals dismissed the appeal for lack of jurisdiction, ruling that the protective order decision was not a final judgment or an appealable collateral order, and denied Maxwell's motion to consolidate the criminal appeal with the civil appeal.
EFTA00030926.pdf
This document is an email chain between the US Attorney's Office (SDNY) and Ghislaine Maxwell's defense counsel (Cohen & Gresser LLP) regarding discovery disputes in early 2021. The correspondence details logistical issues with providing Maxwell access to 4TB hard drives at the MDC, disputes over unredacted FBI reports from 2006 found on Jeffrey Epstein's devices, and missing metadata/Bates ranges. The defense specifically notes missing 'flight logs' from a redacted provider and questions the unsealing of a search warrant affidavit referenced in a Daily Beast article. No actual flight data is contained in the document, only a reference to missing logs.
EFTA00030906.pdf
This document contains a chain of emails from August 2020 between the U.S. Attorney's Office (SDNY) and the Metropolitan Detention Center (MDC) regarding the logistics of delivering legal discovery materials to inmate Ghislaine Maxwell. The emails discuss protocols for hard drive delivery, including password protection, authorization memos, and the use of FedEx. There is also a strategic discussion about cumulative loading of discovery onto single disks to prevent the inmate from accumulating too many hard drives in her cell.
EFTA00030411.pdf
This document is an affidavit filed on December 1, 2020, by Assistant US Attorney Lara Pomerantz in the case against Ghislaine Maxwell. It certifies that the prosecution and defense conferred but failed to reach an agreement regarding the defense's request for the MDC Warden (Tellez) to report directly to the Court on Maxwell's conditions of confinement.
EFTA00030094.pdf
A cover letter from the U.S. Attorney's Office (SDNY) to the Metropolitan Detention Center dated March 16, 2021. The letter encloses discovery materials for inmate Ghislaine Maxwell regarding case 20 Cr. 330 (AJN) and requests that she be granted access to these materials.
EFTA00026813.pdf
This document is a letter from the U.S. Department of Justice to Ghislaine Maxwell's defense team, dated October 8, 2020, refuting claims that the government failed to meet discovery obligations. The letter details technical efforts to ensure Maxwell can review digital evidence at the MDC, including the provision of a secure laptop to review 43,500 images seized from Jeffrey Epstein's properties (3,500 of which contain nudity). It also addresses conditions of confinement, confirming Maxwell remains in an isolation cell for safety, undergoes weekly body scans, and has access to commissary food items.
EFTA00025219.pdf
A letter from the U.S. Department of Justice to Judge Alison J. Nathan updating the court on Ghislaine Maxwell's conditions of confinement at the Metropolitan Detention Center (MDC). The letter details her extensive access to discovery review (13 hours/day), attorney communications (25 hours VTC/week), and specific search protocols including strip searches and body scans. It also notes she was weighed on June 3, 2021, at 138 pounds, and receives wellness checks every 15 minutes at night.
EFTA00017832.pdf
This document is a letter from the U.S. Department of Justice to Judge Alison Nathan opposing Ghislaine Maxwell's requests for early disclosure of witness names and court intervention in her confinement conditions. The Government argues the requests are premature given the trial is 11 months away and discovery has just begun, noting they have already produced over 165,000 pages of evidence. The letter also defends the Bureau of Prisons' protocols for Maxwell, stating her monitoring is appropriate for a high-profile inmate facing significant prison time and confirming she has been granted extensive daily access to review discovery materials.
EFTA00017109.pdf
This document is a transcript of a court hearing in the case of United States v. Nicholas Tartaglione. The proceedings focus on a motion by media organizations (NY Post, Daily News, NY Times) to unseal letters regarding Tartaglione's housing conditions at the MCC and MDC. The Judge rules against the Bureau of Prisons and orders the letters unsealed, citing the public interest in BOP conditions and the fact that Tartaglione's background (and connection to the Epstein incident) is already public knowledge. The hearing also touches on trial scheduling and the government's decision not to seek a warrant for a specific telephone.
EFTA00016118.pdf
Attorney Anthony Cecutti writes to Judge Engelmayer regarding his client, Justin Rivera, detailing ongoing issues with accessing discovery materials (via laptop) and legal counsel (via video calls) at the MCC. The letter alleges harassment by MCC staff, who referred to Rivera as 'enemy #1', and criticizes the facility's rigid scheduling. The document concludes by contrasting Rivera's harsh treatment with the extensive accommodations provided to Ghislaine Maxwell at the MDC (access to computers, showers, TV, and 13 hours of discovery review daily), arguing that the disparity is based on race, gender, and class.
EFTA00015753.pdf
This document contains a chain of email correspondence between Ghislaine Maxwell's defense team (Menninger, Everdell) and the US Attorney's Office (SDNY) regarding the logistics of reviewing evidence for case 20 Cr. 330. The discussions focus on scheduling physical evidence reviews at an FBI warehouse in the Bronx and electronic evidence reviews at the 500 Pearl Street courthouse. Key evidence items discussed include massage tables, plaster busts, cash, shredded paper, and thousands of 'highly confidential' nude or partially nude images seized from Jeffrey Epstein's devices and residences.
EFTA00015738.pdf
This document is a chain of email correspondence between Ghislaine Maxwell's defense team (led by Laura Menninger) and the US Attorney's Office (SDNY) regarding the logistics of reviewing evidence for the case US v. Maxwell. The emails discuss the scheduling of Maxwell's transport by Marshals to 500 Pearl Street to review 'Highly Confidential' materials, including 2,100 nude/partially nude images seized from Jeffrey Epstein's electronic devices. The correspondence also details disputes over the transport of physical evidence from an FBI warehouse in the Bronx, specifically mentioning 'bulky' items like massage tables, plaster busts of female torsos, and a stuffed dog, which the government argued were difficult to transport.
DOJ-OGR-00001722.jpg
This document is page 4 of a Government filing (Document 41) in the case of United States v. Ghislaine Maxwell (Case 1:20-cr-00330), dated August 13, 2020. The Government argues against disclosing witness identities prematurely before the July 2021 trial to protect victim privacy. Additionally, the Government rejects the defendant's complaints regarding her confinement conditions at the MDC, asserting that monitoring protocols are appropriate for safety and security, and clarifying that attorney-client calls are visually observed but not audited.
DOJ-OGR-00001716.jpg
This document is a letter from Ghislaine Maxwell's defense counsel to Judge Alison J. Nathan dated August 10, 2020. The defense requests the disclosure of the identities of 'Victims 1-3' to prepare for trial and argues that Maxwell is being subjected to uniquely harsh confinement conditions at the MDC as a direct reaction to the BOP's failure to prevent Jeffrey Epstein's suicide in 2019. The letter details Epstein's timeline of detention and death to contextualize the extreme surveillance and isolation Maxwell is facing.
DOJ-OGR-00001708.jpg
This is page 4 of a legal filing dated August 10, 2020, addressed to Judge Alison J. Nathan. The defense argues for the disclosure of the identities of Victims 1-3 and protests the harsh confinement conditions of Ghislaine Maxwell at the MDC. The document explicitly claims Maxwell's treatment (isolation, 24-hour surveillance, suicide watch protocols) is a direct reaction by the BOP to the suicide of Jeffrey Epstein at the MCC in 2019.
DOJ-OGR-00001590.jpg
This is page 10 of a legal filing from July 10, 2020, in the case United States v. Ghislaine Maxwell. The text argues for release or specific detention conditions based on the high risk of COVID-19 in prisons, citing statistics and prior court rulings. It specifically notes that Maxwell was transferred to the Metropolitan Detention Center (MDC) by the BOP on July 6, 2020.
DOJ-OGR-00001450.jpg
This document is page 10 of a court filing from May 27, 2021, discussing the conditions of Ghislaine Maxwell's confinement at the MDC. It details a May 5, 2021, letter from the Government to Judge Nathan explaining that Maxwell is subject to flashlight checks every 15 minutes due to an 'enhanced security schedule,' compared to every 30 minutes for SHU inmates and hourly for general population. The document asserts these checks are for safety purposes, specifically to ensure the inmate is breathing and not in distress, noting that while Maxwell is not on suicide watch, her high-profile charges warrant increased monitoring.
DOJ-OGR-00001435.jpg
This document is a status letter from the U.S. Attorney's Office (SDNY) to Judge Alison J. Nathan, dated May 5, 2021, regarding the case United States v. Ghislaine Maxwell. It details the protocols for flashlight security checks at the Metropolitan Detention Center (MDC), explaining that checks are generally conducted every 30 minutes in the SHU and hourly in the general population. However, the letter specifies that Ghislaine Maxwell is subject to checks every 15 minutes because she is on an 'enhanced security schedule,' though not on suicide watch.
DOJ-OGR-00020660.jpg
This document is a court docket report from late April 2021 for the case US v. Ghislaine Maxwell. It records her 'Not Guilty' plea, sets scheduling deadlines for pretrial motions and victim disclosures, and details a dispute where Maxwell's defense (Sternheim) alleges MDC guards wrongfully seized her confidential legal documents. Judge Nathan ordered MDC legal counsel to show cause regarding this incident.
DOJ-OGR-00001870.jpg
This is a letter dated October 29, 2020, from attorney Bobbi C. Sternheim to Warden Heriberto Tellez of the Metropolitan Detention Center (MDC). The attorney is writing on behalf of her client, Ghislaine Maxwell, to protest the 'extraordinarily restrictive conditions' of her detention, which are compared to solitary confinement and death row. The letter argues that these harsh measures are not a response to any threat Maxwell poses but are an overreaction by the Bureau of Prisons (BOP) to its failure to prevent the death of Jeffrey Epstein at a different facility.
DOJ-OGR-00019884.jpg
This legal document argues that the risks of COVID-19 to inmates in correctional facilities have significantly increased, citing a doubling of cases and a 73% increase in deaths in the last month. It highlights that the virus is now spreading in the Metropolitan Detention Center (MDC), where Ms. Maxwell was recently transferred by the Bureau of Prisons. The document uses prior court opinions and news reports to support the claim of heightened risk and the inevitability of community spread in such facilities.
DOJ-OGR-00010586.jpg
This page from a Government sentencing memorandum (Case 1:20-cr-00330-PAE) argues that Ghislaine Maxwell received preferential treatment at the MDC, including private amenities and access to counsel, refuting her claims of harsh conditions. It highlights inconsistencies in her complaints regarding general population and COVID-19 restrictions. A footnote addresses a 'credible death threat' claim, revealing it was merely an inmate's hypothetical remark about killing Maxwell for a million dollars, which an investigation deemed not credible.
DOJ-OGR-00010516.jpg
This document is a letter dated August 24, 2021, from Dr. Alexander S. Bardey of Fifth Avenue Forensics to Ghislaine Maxwell's attorneys, Laura Menninger and Bobbi Sternheim. Dr. Bardey outlines the process of an ongoing forensic psychiatric evaluation of Ms. Maxwell, conducted to assess her mental state and flight risk in relation to a pending bail application. The evaluation included 14 meetings with Maxwell, a review of her history and legal documents, and a collateral interview with her counsel and acquaintance, Leah Saffian.
DOJ-OGR-00020379.jpg
This document is a page from a government legal filing (Case 21-58) responding to Ghislaine Maxwell's complaints regarding her incarceration conditions at the MDC. The text refutes Maxwell's claims of sewage flooding by clarifying that the cited precedent (Tiffany Days) occurred at the MCC, not the MDC. Additionally, it counters her claim of 'solitary confinement' by detailing her 13-hour daily access to a day room equipped with computers, a phone, and a TV, while noting she requires protective custody for her safety.
DOJ-OGR-00020369.jpg
This document is page 11 of a court filing dated May 27, 2021, concerning Ghislaine Maxwell's confinement conditions at the Metropolitan Detention Center (MDC). It details the Government's response regarding Maxwell's request for an eye mask and a dispute over nighttime flashlight checks. Judge Nathan denied Maxwell's request to modify the monitoring schedule on May 14, 2021, noting that Maxwell's claims were unsupported by an affidavit and that flashlight checks are standard procedure for all inmates.
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