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"Conditions of Confinement"
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EFTA00029584
Dataset 8
2020-01-20
3p
1,385w
…Concerning Mr. Avenatti's Prison Conditions Dear Judge Gardephe: We write to inform the Court of Mr. Avenatti's conditions as a pretrial detainee and to request that the Court inquire into his custody status and direct the Bureau of Prisons to consider his immediate removal to general population. Under Mr. Avenatti's current
conditions of confinement
, we cannot effectively prepare for trial and Mr. Avenatti cannot meaningfully assist in his defense. As the Court is aware, Mr. Avenatti was…
https://www.justice.gov/epstein/files/DataSet%208/EFTA00029584.pdf
EFTA00013225
Dataset 8
2020-09-21
10p
3,286w
…produced to date. Second, we write to request that the government set up a time at the earliest convenience when Ms. Maxwell and defense counsel can review the documents marked as "Highly Confidential" in the discovery materials. Third, we write to register our objection to the onerous
conditions of confinement
to which Ms. Maxwell is subjected, which are entirely unique to Ms. Maxwell. We request that the government intercede directly with the BOP to improve these conditions, as set forth…
https://www.justice.gov/epstein/files/DataSet%208/EFTA00013225.pdf
EFTA00154512
Dataset 9
2000-07-20
45p
12,732w
…place over 25 years ago. Far from creating a flight risk, the lack of corroboration only reinforces Ms. Maxwell's conviction that she has been falsely accused and strengthens her long-standing desire to face the allegations against her and clear her name in court. • Oppressive
conditions of confinement
Ms. Maxwell has now been detained for over 150 days in the equivalent of solitary confinement since she was indicted and arrested on July 2, 2020, despite the fact that she…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00154512.pdf
EFTA00094289
Dataset 9
2000-07-20
45p
14,069w
…testimony about events that took place over 25 years ago. Far from creating a flight risk, the lack of corroboration only reinforces Ms. Maxwell's conviction that she has been falsely accused and strengthens her long-standing desire to face the allegations against her and clear her name in court. • Oppressive
conditions of confinement
. Ms. Maxwell has now been detained for over 150 days in the equivalent of solitary confinement since she was indicted and arrested on July 2, 2020…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00094289.pdf
EFTA00087980
Dataset 9
2020-09-21
10p
3,335w
…produced to date. Second, we write to request that the government set up a time at the earliest convenience when Ms. Maxwell and defense counsel can review the documents marked as "Highly Confidential" in the discovery materials. Third, we write to register our objection to the onerous
conditions of confinement
to which Ms. Maxwell is subjected, which are entirely unique to Ms. Maxwell. We request that the government intercede directly with the BOP to improve these conditions, as set forth…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00087980.pdf
EFTA01687577
Dataset 10
2019-02-03
38p
8,752w
…of Sadiq Motiwala, I expressed concerns with MCC New York in regards to staff shortages, staff from other departments being "augmented" to fill in for correctional officer vacancies on a regular basis,
conditions of confinement
at MCC and various other matters related to the institution. I stated in my testimony and also in my Declaration that MCC New York or any other federal prison could not prevent anyone who is persistent from taking their own life. At best, they could…
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01687577.pdf
EFTA00017820
Dataset 8
2020-11-24
1p
133w
Subject:
Call tomorrow re Maxwell
…0000 Attachments: 2020.11.24_AJN_order re_meet_&_confer re_MDC_conditions.pdf Hi In response to the letter we filed yesterday, today Maxwell's counsel filed her own letter demanding that Judge Nathan order the Warden of the MDC to appear for a court proceeding to address the defense's complaints about Maxwell's
conditions of confinement
. Judge Nathan endorsed that letter with an order that the parties confer and provide another update letter by Tuesday 12/1…
https://www.justice.gov/epstein/files/DataSet%208/EFTA00017820.pdf
EFTA00029695
Dataset 8
2021-05-17
1p
181w
Subject:
Vir i . n. wont
From:
David Oscar Markus <
[email protected]
>
…Vir i . n. wont Date: Mon, 17 May 2021 17:14:21 +0000 Attachments: 2021.05.14,_GM,order regarding_sleeping_conditions.pdf One of Maxwell's attorneys sent the below email. I've attached the Friday ruling that he is referring to which is not a bail order and instead relates to the
conditions of confinement
. As you know, he already appealed Judge Nathan's prior bail orders. (After he filed the bail appeal in the Circuit, Judge Nathan…
https://www.justice.gov/epstein/files/DataSet%208/EFTA00029695.pdf
EFTA00013303
Dataset 8
2020-12-30
2p
400w
Subject:
RE: Ghislaine Maxwell 02879-509
From:
I
From: To: Cc: Subject: RE: Ghislaine Maxwell 02879-509 Date: Wed, 30 Dec 2020 18:21:52 +0000 I have reached out to MDC legal counsel to discuss the two emails you sent me today regarding Ms. Maxwell's
conditions of confinement
. I will reach back out to you once I have had that conversation. Thank you and Happy New Year, Assistant United States Attorney Southern District of New York New York, NY 10007 From: I Sent: Wednesday, December 30…
https://www.justice.gov/epstein/files/DataSet%208/EFTA00013303.pdf
EFTA00024998
Dataset 8
2021-01-09
1p
239w
Subject:
Re: Epstein FOIA Atty Visit Logs and Count Slips
From:
"=IM, (USANYS)" <I >
To:
" , (USANYS)" <I
From: "=IM, (USANYS)" <I > To: " , (USANYS)" <I Cc: ' llnIalYS)" <I k " )" Subject: Re: Epstein FOIA Atty Visit Logs and Count Slips Date: Sat, 09 Jan 2021 17:51:12 +0000 Sure, worked on some
conditions of confinement
stuff and recently was added to handle same De u Chief, White Plains Division O: C: On Jan 9, 2021, at 10:59, , (USANYS) < > wrote: Got it. Thanks, If it's alright, I'm going to loop in in Civ…
https://www.justice.gov/epstein/files/DataSet%208/EFTA00024998.pdf
EFTA00027871
Dataset 8
2021-04-01
1p
99w
Subject:
Maxwell update to court - due 4/6
From: Subject: Maxwell update to court - due 4/6 Date: Thu, 01 Apr 2021 20:49:10 +0000 Attachments: MDC Conditions_Letter_2-16_FINAL.pdf Hi Our next update regarding Maxwell's
conditions of confinement
is due on Tuesday 4/6. Is there a time tomorrow or Monday when we could please have a call to check in and get an update? In particular, it would be useful to talk through the issues raised in defense counsel's most…
https://www.justice.gov/epstein/files/DataSet%208/EFTA00027871.pdf
EFTA00023918
Dataset 8
2021-06-16
2p
357w
Subject:
FW: US v. Maxwell, 52 20 Cr. 330 (AJN)
From:
"
…you. On Jun 7, 2021, at 9:42 PM, wrote: Good evening, Attached please find the Government's letter updating the Court about the defendant's
conditions of confinement
at the MDC. The Government is still waiting to hear from defense counsel whether they are seeking redactions. Accordingly, the Government is submitting the letter by email to the Court temporarily under seal to give the defense an opportunity to propose and justify any redactions it deems necessary. We will file…
https://www.justice.gov/epstein/files/DataSet%208/EFTA00023918.pdf
EFTA00138815
Dataset 9
2019-07-03
41p
9,046w
…of Sadiq Motiwala, I expressed concerns with MCC New York in regards to staff shortages, staff from other departments being "augmented" to fill in for correctional officer vacancies on a regular basis,
conditions of confinement
at MCC and various other matters related to the institution. I stated in my testimony and also in my Declaration that MCC New York or any other federal prison could not prevent anyone who is persistent from taking their own life. At best, they could…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00138815.pdf
EFTA00017821
Dataset 8
2020-11-24
2p
865w
…using the CorrLinks email system to communicate with family and counsel. However, the letter presents an incomplete picture of Ms. Maxwell's
conditions of confinement
. The government fails to mention a variety of issues brought to the attention of the MDC, including but not limited to the fact: that all email correspondence between Ms. Maxwell and counsel was deleted in advance of the 180-day period, when deletion is expected to occur; that after being administered two nasal swab tests…
https://www.justice.gov/epstein/files/DataSet%208/EFTA00017821.pdf
EFTA00020659
Dataset 8
2019-07-25
2p
164w
Subject:
RE: BOP statement on Epstein
From:
(USANYS)"<
To:
(USANYS)" USANYS)"
…at MCC New York and not in a local hospital as has been reported. As with all inmates, for privacy and security reasons, we do not share information on an inmate's medical status or their
conditions of confinement
. L1 Adam Klasfeld Retweeted (li) Josh Gerstein 41, @joshgerstein MS I IN: I his statement from the federal Bureau of Prisons re Jeffrey Epstein. (The MCC is the Metropolitan Correctional Center in Manhattan.) 43 u i c7, COO Public Affairs US…
https://www.justice.gov/epstein/files/DataSet%208/EFTA00020659.pdf
EFTA00011142
Dataset 8
2020-11-19
3p
1,346w
Subject:
Notes from 2020.11.19 Call with Sternheim, Everdell, and Cohen
…if GM remains in, it will likely be the first of many calls in light of current COVID situation; would need to file under seal and would like your consent as well o Show real evidence of threats to her and family members and those close to her • M: really appreciate you coming to us with concerns about
conditions of confinement
and opening dialogue about bail application; in terms of bail application, we are happy to listen and take a…
https://www.justice.gov/epstein/files/DataSet%208/EFTA00011142.pdf
EFTA00030411
Dataset 8
2020-11-30
2p
262w
…defendant, Ghislaine Maxwell, regarding defense counsel's request that the warden of the Metropolitan Detention Center ("MDC") report directly to the Court and counsel on the defendant's
conditions of confinement
, and that the parties have been unable to reach agreement. 3. In particular, on November 30, 2020, the Government asked defense counsel whether they would consent to MDC legal counsel addressing the Court and counsel directly in writing on the defendant's
conditions of confinement
. On December 1, 2020…
https://www.justice.gov/epstein/files/DataSet%208/EFTA00030411.pdf
EFTA00010196
Dataset 8
2020-12-01
2p
693w
…detention. (Dkt. No. 76). Over the past week, the Government has spoken with MDC legal counsel regarding the defendant's
conditions of confinement
and has tried to gather additional information regarding the concerns raised by the defendant, which the Government has shared with defense counsel. The Government has also conferred with defense counsel three times regarding the same, as well as the defense's request relating to MDC Warden Heriberto Tellez. The parties have been unable to reach agreement. Our…
https://www.justice.gov/epstein/files/DataSet%208/EFTA00010196.pdf
EFTA00027268
Dataset 8
2020-11-23
22p
6,962w
…detention. (Dkt. No. 76). Over the past week, the Government has spoken with MDC legal counsel regarding the defendant's
conditions of confinement
and has tried to gather additional information regarding the concerns raised by the defendant, which the Government has shared with defense counsel. The Government has also conferred with defense counsel three times regarding the same, as well as the defense's request relating to MDC Warden Heriberto Tellez. The parties have been unable to reach agreement. Our…
https://www.justice.gov/epstein/files/DataSet%208/EFTA00027268.pdf
EFTA00027098
Dataset 8
2019-08-13
2p
356w
Subject:
Re: Epstein OIG/FBI--Document Preservation
…me know immediately. Thanks, M From: Sent: Monday, August 12, 2019 11:35 AM Subject: Epstein OIG/FM—Document Preservation Please forward this to everyone who might have any documents relating to the Epstein suicide, and cc me: Please make sure to preserve any documents you may have relating to Epstein's
conditions of confinement
. • Your emails will be adequately preserved, for present purposes, by the regular three-year backup. But let me know if you have any or not.…
https://www.justice.gov/epstein/files/DataSet%208/EFTA00027098.pdf
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