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This document is a letter from attorney Scott A. Srebnick to Judge Paul G. Gardephe regarding the prison conditions of Michael Avenatti at MCC-New York. The letter details Avenatti's placement in the Special Housing Unit (SHU) on the 10-South floor (formerly El Chapo's cell), citing extreme cold, isolation, and lack of resources as impediments to trial preparation. The defense requests Avenatti be moved to the general population and granted standard access to legal materials and communication. The text alludes to 'recent issues at the institution,' likely a reference to Jeffrey Epstein's suicide at the same facility months prior.