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A letter from defense attorney Christian Everdell to Judge Alison Nathan requesting a court order for the Bureau of Prisons to grant Ghislaine Maxwell weekend and holiday access to a discovery laptop. The defense argues that the standard prison computer lacks necessary software to review voluminous evidence before the July 2021 trial, noting that the government does not object to the request. The letter highlights that Maxwell previously had full access during a COVID quarantine period in late 2020.
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A legal letter from attorney Christian R. Everdell to Judge Alison J. Nathan requesting a court order for the Bureau of Prisons to grant Ghislaine Maxwell weekend and holiday access to a discovery review laptop. The letter argues that current prison computers lack necessary software to review millions of documents before the July 12, 2021 trial, and notes that the government does not object to this request.
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A letter motion dated December 31, 2020, from Ghislaine Maxwell's attorney, Christian R. Everdell, to Judge Alison J. Nathan requesting a two-week extension for pretrial motions. The request cites a large volume of discovery and difficulties conferring with Maxwell due to her 14-day quarantine and the suspension of legal visits at the MDC caused by COVID-19. Judge Nathan signed and ordered the new schedule on January 5, 2021.
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A letter motion dated December 31, 2020, from Ghislaine Maxwell's attorney, Christian R. Everdell, to Judge Alison J. Nathan requesting a two-week extension for pretrial motions. The request cites a large volume of discovery and difficulties conferring with Maxwell due to her 14-day quarantine and the suspension of legal visits at the MDC caused by COVID-19. Judge Nathan signed and ordered the new schedule on January 5, 2021.
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A legal letter filed on December 31, 2020, by defense attorney Christian Everdell to Judge Alison Nathan requesting a two-week extension for pretrial motions in the case of United States v. Ghislaine Maxwell. The request cites a large volume of discovery and difficulties conferring with Maxwell due to her recent 14-day quarantine and the suspension of legal visits at the MDC caused by COVID-19. The prosecution consented to the request, and a new schedule is proposed leading up to a July 12, 2021 trial date.
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This document is a letter dated December 31, 2020, from Christian R. Everdell, an attorney for Ghislaine Maxwell, to Judge Alison J. Nathan. The attorney requests a two-week extension for filing pretrial motions in the case of United States v. Ghislaine Maxwell. The justification for the request is the large volume of discovery materials and the fact that Maxwell was recently placed in a 14-day COVID-related quarantine at MDC, which has suspended in-person legal visits.
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This document is page 20 of a court order filed on December 30, 2020, in Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell). The Court denies the Defendant's request for release, reaffirming that she presents a flight risk and determining that her conditions of confinement at the MDC (including COVID-19 lockdowns) do not violate her constitutional rights or justify release. The text notes that the Defendant has received more time than other inmates to review discovery and communicate with counsel.
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This is page 20 of a court order filed on December 30, 2020, in the case of United States v. Ghislaine Maxwell (identified by case number 1:20-cr-00330-AJN). The Court denies the defendant's request for release, reaffirming that she presents a flight risk and rejecting arguments that her conditions of confinement at the MDC (specifically relating to COVID-19 lockdowns and attorney access) violate her constitutional rights. The document notes that she has received significant time to review discovery compared to other inmates.
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This legal document is a filing on behalf of Ms. Maxwell requesting release on bail. It argues against the government's assertion that she is a flight risk, citing her proposed bail package and extradition waivers, and claims the government's standard is impossibly high. The filing also uses the recent surge of COVID-19 cases at the MDC and the suspension of her legal visits as further justification for her release, arguing her constitutional rights are being eroded.
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This document is the Table of Contents for a legal filing (Document 103) dated December 23, 2020, in the case against Ghislaine Maxwell (1:20-cr-00330-AJN). The filing argues for Maxwell's release on bail, citing her ties to the U.S. (including a redacted spouse), the pledging of all assets, the weakness of the government's case relying on only three witnesses, and health risks due to a COVID surge at the MDC detention center.
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This legal document, filed by the Government, argues against a defendant's release from the Metropolitan Detention Center (MDC). It asserts that the MDC provides adequate care, including meals and medical checks, and that the security searches she complains about are standard procedure. The document also dismisses COVID-19 concerns, noting the defendant was quarantined and tested negative after a potential exposure and has no underlying health conditions, making her release unwarranted.
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This legal document, filed on December 18, 2020, is a response from the Government arguing that the defendant, housed at the MDC, has adequate resources to prepare for trial. It refutes the defense's claim to the contrary by detailing provisions such as daily VTC calls with counsel, access to discovery on hard drives, and the provision of a dedicated laptop. The document also explains how access to this equipment is managed within the MDC, including during a recent period of quarantine.
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This legal document is a filing by the Government arguing for the continued detention of the defendant, asserting she is an extreme flight risk. The Government cites her foreign citizenship in a non-extraditing country, substantial international ties, financial resources, and the seriousness of the charges involving minor victims. The filing also refutes the defense's complaints about the conditions of confinement, stating the defendant has ample time and access to communicate with her counsel and review discovery materials.
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This document is page 29 (filed 12/18/20) of a Government opposition to a renewed bail application in the case of United States v. Ghislaine Maxwell (Case 1:20-cr-00330-AJN). The Government argues against release, citing the defendant's multiple foreign citizenships (including a non-extradition country), substantial wealth, and demonstrated sophistication in hiding assets as indicators of extreme flight risk. The document also defends the conditions of confinement at the MDC, noting the defendant has 13 hours a day to review discovery and access to attorney communications.
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This document is page 13 of a legal filing (Case 1:20-cr-00330-AJN) dated December 14, 2020, analyzing the potential human rights objections Ghislaine Maxwell might raise against extradition to the US. The text specifically argues that Maxwell is unlikely to succeed in claiming a violation of Article 3 of the ECHR regarding prison conditions, citing numerous legal precedents where such claims were rejected. Footnotes reference specific cases and US detention facilities (MDC and MCC) in New York.
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This page from a legal filing (Case 1:20-cr-00330-AJN) outlines the defense's grievances regarding Ghislaine Maxwell's inability to access readable discovery materials due to technical failures with hard drives provided by the government. It also details harsh prison conditions at the MDC, specifically noting that Maxwell was placed in quarantine after exposure to a COVID-positive staffer and subjected to invasive searches that increased her health risks.
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This legal document, filed on behalf of Ms. Maxwell, argues that her pretrial detention conditions at the MDC are excessively punitive and inappropriate. Her counsel asserts these conditions—including de facto solitary confinement and constant surveillance—are an overreaction to Epstein's death, are disproportionate for a non-violent detainee, and are impeding her ability to prepare a defense. The document references multiple unsuccessful attempts by counsel to remedy the situation through communication with the MDC, its legal department, and prosecutors.
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This document is page 35 (filed as page 41 of 45) of a legal motion arguing for Ghislaine Maxwell's release on bail. The defense argues that Maxwell is not a flight risk and that her current detention at the MDC amounts to 'de facto solitary confinement' under conditions more severe than supermax prisons or death row, which impedes her ability to prepare her defense. The text cites legal precedent regarding bail standards and claims wardens have never seen such restrictive regulations.
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This document is page 12 of a legal filing (Document 97) from December 14, 2020, regarding Ghislaine Maxwell's bail application. It focuses on her strong family ties and marriage, citing redacted exhibits (B, C, F) that attest to her loving relationship with her husband and commitment to the US. The text explains that her spouse (whose name is redacted) initially did not co-sign her bail due to fear of 'ferocious media aggression' but is now coming forward with all their assets due to concerns over her treatment at the MDC.
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This is page 5 (filed as page 11 of 45) of a defense motion arguing for Ghislaine Maxwell's release on restrictive bail. The defense argues that the government lacks corroborating documentary evidence, relying instead on old witness testimony, and asserts that Maxwell is suffering under oppressive confinement conditions at the MDC, including isolation and COVID-19 risks. The document also references extradition laws in the UK and France and complaints about discovery failures.
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This document is an excerpt from a court transcript dated December 10, 2020, detailing a discussion between attorney Mr. Cohen and The Court. Mr. Cohen describes the severe, solitary confinement-like conditions his client endured at the MDC, including denial of basic rights and access to legal counsel, and requests more time to address the court's concerns regarding financial matters. The Court seeks clarification on the nature of the client's detention, specifically if there was consent.
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This document is page 5 of a court transcript from December 10, 2020, in the case against Ghislaine Maxwell (Case 1:20-cr-00330-AJN). The proceeding is conducted via videoconference due to remote access protocols, with Maxwell participating from the MDC in Brooklyn. The Judge establishes technical connectivity and explains the procedure for Maxwell to speak privately with her attorney, Mr. Cohen, in a digital breakout room, before moving to discuss a waiver of physical presence.
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This legal filing from December 2020 outlines complaints regarding the conditions of Ghislaine Maxwell's confinement at the MDC. The defense argues she is being deprived of communication with family and legal counsel, citing specific issues such as deleted legal emails, physical barriers during visits, denial of basic needs during meetings, and the intentional damaging of a hard drive by an officer. The document concludes that these restrictions are arbitrary and disproportionate, noting Maxwell's good behavior and certifications as a suicide counselor and teacher.
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This is page 2 of a legal filing from the US Attorney's Office for the SDNY regarding the detention conditions of Ghislaine Maxwell. The prosecutors argue that Warden Tellez should provide a first-hand accounting of why Maxwell is subject to strict surveillance measures (body scans, flashlight checks) despite 24/7 camera monitoring, noting that the MDC Legal Department would only provide second-hand information.
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This document is a legal letter from defense attorney Bobbi C. Sternheim to Judge Alison J. Nathan, filed on November 24, 2020, regarding the pretrial detention conditions of Ghislaine Maxwell at the MDC. The defense alleges excessive surveillance, sleep deprivation via flashlight checks every 15 minutes, and isolation, requesting that Warden Heriberto Tellez be summoned to address the court. The document includes a hand-signed order by Judge Nathan requiring the parties to meet and confer regarding the request for the Warden to address these concerns.
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