This document is an internal email chain within the U.S. Attorney's Office for the Southern District of New York (SDNY) dated August 13, 2020. It discusses a filing deadline regarding a defense motion to move Ghislaine Maxwell to general population or improve her detention conditions. The Chief Public Information Officer highlights that 'Main (OPA)' is keenly interested in the filing because of the Attorney General's previous response to Jeffrey Epstein's suicide and current pressure from Congressional Republicans regarding Maxwell's safety.
This document is a court order from Judge Alison J. Nathan in the case of United States v. Ghislaine Maxwell, dated May 3, 2021. The order grants Maxwell's request for a continuance of the trial date from July 2021 to Fall 2021 due to the filing of a superseding indictment (S2) which added new charges, extended the conspiracy timeframe to 2004, and identified a fourth minor victim. The judge cited the need for the defense to review new discovery and the ongoing logistical challenges of the COVID-19 pandemic as reasons for the delay.
This document is an internal email from a Paralegal Specialist at the U.S. Attorney's Office (SDNY) dated October 11, 2021. The email transmits draft letters addressed to the MDC (Metropolitan Detention Center) regarding 'Maxwell' (Ghislaine Maxwell), as indicated by the attachment filenames. The email includes the sender's signature block with the SDNY office address.
An email chain from June 2021 between Ghislaine Maxwell's attorney, Bobbi Sternheim, and prison officials (likely MDC/BOP). Sternheim complains about the conditions of Maxwell's confinement, specifically alleging that guards repeatedly woke Maxwell due to shivering from cold temperatures only to subsequently confiscate her blankets. The correspondence also addresses technical failures with Video Teleconferencing (VTC) equipment hindering attorney-client preparation and alleges unprofessional behavior by guards.
This document is an email dated December 2, 2020, from an Assistant United States Attorney in the Southern District of New York regarding the 'Maxwell' case. The email discusses an attached order from Judge Nathan which requires the Metropolitan Detention Center (MDC) legal team to file a letter with the court by the following Friday. The sender requests a call to discuss the matter.
An email chain from December 1, 2020, between Assistant United States Attorneys in the Southern District of New York (USANYS). The topic is drafting a letter regarding 'GM' (Ghislaine Maxwell) and a defense request concerning the MDC Warden. The prosecutors discuss editing the draft to explicitly quote 'Bobbi' (likely defense attorney Bobbi Sternheim) rather than characterizing her views.
An email thread from December 18, 2020, between staff at the U.S. Attorney's Office (SDNY) regarding a correction to the discovery production for Ghislaine Maxwell. A paralegal identified incorrect Bates numbers on seven items from previous productions, re-stamped them, and prepared a disc to be sent to Maxwell at the Metropolitan Detention Center (MDC) and emailed to defense counsel.
This document contains an email chain and Amazon receipts from November 2020 regarding the purchase and preparation of a laptop for Ghislaine Maxwell ('Maxwell Laptop'). The U.S. Attorney's Office (SDNY) purchased an HP Pavilion laptop, DVD drive, and Microsoft Office software. The emails detail the technical modifications made to the laptop to meet Bureau of Prisons (BOP) standards, specifically the physical removal of Wi-Fi, Bluetooth, and Ethernet capabilities, to allow Maxwell to review discovery materials at the Metropolitan Detention Center (MDC).
An email from attorney Bobbi C. Sternheim dated November 1, 2020, addressing the harsh confinement conditions of Ghislaine Maxwell at the MDC. Sternheim describes the conditions as including cold, moisture, and sewage stench, and notes that Maxwell has been denied a blanket and a cup for water. She compares this treatment unfavorably to her experience with terrorism and capital murder suspects in supermax facilities.
This document is an email chain from November 5-6, 2020, between the FBI (specifically Special Agent Amanda Young and others) and the US Attorney's Office for the Southern District of New York. The correspondence coordinates logistics for FBI agents to assist with a visit at the Metropolitan Detention Center (MDC) where inmate Ghislaine Maxwell and her attorney were scheduled to review the contents of a laptop. The visit was scheduled for November 6, 2020, from 9:15 AM to 3:00 PM.
This document is an email chain from November 5, 2020, involving Ghislaine Maxwell's attorney, Bobbi C. Sternheim, and BOP officials. Sternheim acknowledges that Maxwell is now allowed a water mug and snacks but requests she be moved to an interior cell at MDC Brooklyn due to moisture and cold air degrading her legal paperwork and affecting her health. BOP officials circulate the request internally to schedule a discussion.
This document is an email dated November 6, 2021, concerning the transmission of legal discovery material ('3500 material') in the case U.S. v. Ghislaine Maxwell. The sender confirms that files have been uploaded to USAfx for the defense team and that a physical drive will be prepared and sent via FedEx. The email includes several attachments referencing indices, non-testifying witness material, and cover letters.
An email chain from October 2021 between the US Attorney's Office (SDNY) and Ghislaine Maxwell's defense team regarding discovery production in the case US v. Maxwell. The correspondence confirms that discovery materials were shared via USAfx and discusses logistics for providing digital copies (CD or hard drive) to Maxwell at the Metropolitan Detention Center (MDC).
This document is an email chain from November 1-2, 2020, detailing a complaint from Ghislaine Maxwell's attorney, Bobbi Sternheim, regarding prison conditions at the MDC. Sternheim alleges the cell is cold, smells of sewage, has moisture issues, and that Maxwell was denied basic items like a water mug and extra blanket. Government officials investigated and responded internally that temperature checks showed the cell was 71-74 degrees (warmer than the 68-degree target), no moisture or smell was found, and she was provided an extra blanket.
Court order from Judge Alison J. Nathan in the case of USA v. Ghislaine Maxwell denying the defendant's request to summon Warden Heriberto Tellez to personally answer questions regarding confinement conditions. The order mandates the Government to provide written status updates every 60 days regarding Maxwell's access to legal materials, counsel, and the frequency of searches.
This document is a letter from Ghislaine Maxwell's attorney, Bobbi Sternheim, to Judge Alison Nathan, dated November 24, 2020. It details complaints about Maxwell's detention conditions at the MDC, including harsh quarantine measures after COVID-19 exposure, lack of basic hygiene items like soap and a toothbrush, deletion of legal emails, and sleep deprivation due to flashlight checks every 15 minutes. The letter concludes with a request to summon Warden Heriberto Tellez, followed by a court order from Judge Nathan requiring the parties to meet and confer on the matter.
This document is an email dated November 24, 2020, from an Assistant US Attorney in the SDNY to a redacted recipient. The email discusses a legal development where Ghislaine Maxwell's counsel demanded the MDC Warden appear in court regarding confinement conditions, resulting in an order from Judge Nathan for the parties to confer and update the court by December 1. The sender requests a call the following day to discuss the matter before the Thanksgiving holiday.
This document is an email chain between Ghislaine Maxwell's defense counsel (Christian Everdell) and the US Attorney's Office (SDNY) regarding discovery production disputes in November 2020. The defense expresses significant frustration regarding technical issues with hard drives provided to Maxwell at the MDC, including broken drives and a lack of consolidation, as well as severe restrictions on the hours Maxwell is permitted to use a laptop to review over 2 million pages of evidence. The prosecution responds by offering to consolidate materials onto a single drive and explaining that the limited laptop access (8:30am-3:30pm) is due to MDC security protocols requiring lieutenant supervision.
This document is a Court Order filed on October 15, 2021, by District Judge Alison J. Nathan in the case of United States v. Ghislaine Maxwell. The Judge acknowledges receipt of a letter from the Defendant regarding issues with legal mail delivery at the MDC and orders the Government to respond by 5:00 p.m. that same day.
This document is an email chain from November 24, 2021, among staff at the U.S. Attorney's Office for the Southern District of New York (SDNY). The emails discuss the urgent review and preparation of discovery materials (referred to as 'productions', including '3500' material and 'Rule 16' material) related to the 'USvEpstein' case (specifically the trial of Ghislaine Maxwell, denoted as 'GM'). The team was coordinating to load these files onto a hard drive to be sent via FedEx to the defense team before a 4 PM pickup deadline. The document includes internal DOJ network file paths pointing to trial materials.
This document is an email dated December 4, 2020, from an Assistant United States Attorney in the Southern District of New York to Judge Nathan's chambers. The email submits a letter from the Metropolitan Detention Center (MDC) legal counsel regarding the case US v. Maxwell (Ghislaine Maxwell) and notes that the government has no objection to the letter being publicly docketed despite not being filed on ECF by the MDC.
An email chain from October 29, 2021, regarding urgent issues with Ghislaine Maxwell's legal mail at the MDC. Attorney Bobbi Sternheim threatens an order to show cause because Maxwell has not received legal mail in over a week despite USPO tracking showing items available for pickup. The document includes a signature block for Isabel Maxwell acting as a paralegal for Leah Saffian, Inc.
An email from attorney Bobbi C. Sternheim regarding urgent issues with legal mail delivery to Ghislaine Maxwell at the MDC. Sternheim provides USPS tracking evidence showing four items waiting for pickup in Brooklyn and threatens court action if the MDC does not retrieve them. The document includes screenshots of the tracking information and a signature block for Isabel Maxwell, a paralegal.
An email dated December 18, 2020, from an Assistant US Attorney (SDNY) to Ghislaine Maxwell's defense counsel. The email provides replacement discovery materials to correct documents that were inadvertently labeled with incorrect Bates numbers in a previous production. It notes that a physical copy on disc is being sent to the MDC for Maxwell.
This document is an internal email chain among SDNY prosecutors dated December 21, 2020. It discusses a legal issue in the case *United States v. Rivera et al.*, where Judge Engelmayer expressed frustration that defendant Justin Rivera (at MCC) received significantly less access to discovery and legal counsel compared to Ghislaine Maxwell (at MDC). The emails detail the stark difference in hours allowed (91 hours/week for Maxwell vs 21 hours/week for Rivera) and mention the seizure of 60 devices and an entire FBI file from a prior Florida investigation in the Maxwell case.
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