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Case 1:20-cr-00330-AJN Document1 Filed 06/29/20 Page 2 of 18
Epstein’s residences in different states, which MAXWELL knew and
intended would result in their grooming for and subjection to
sexual abus
Case 21-770, Document 73, 05/27/2021, 3109708, Page22 of 24
38. The only question even arguably before this Court at this juncture
is whether Judge Nathan committed clear error when detaining Maxwell
Case 21-770, Document 73, 05/27/2021, 3109708, Page17 of 24
of confinement do not warrant temporary release. Nothing in Maxwell’s renewed
motion alters that conclusion.
32. “Asa general matter, this
Case 21-770, Document 73, 05/27/2021, 3109708, Page14 of 24
“the weight of the evidence against the person”; and (3) the “history and
characteristics of the person.” 18 U.S.C. § 3142(g).
26. This Co
Case 21-770, Document 73, 05/27/2021, 3109708, Page11 of 24
increased stress of a high-profile case, and her sleeping situation in a cell by herself
without acellmate. (Ud. at2). Third, the Governmen
Case 21-770, Document 73, 05/27/2021, 3109708, Page12 of 24
justifying the MDC’s decision to monitor Maxwell more frequently at night than
other inmates. (/d.). With respect to eye coverings, Judge N
Case 21-770, Document 73, 05/27/2021, 3109708, Page10 of 24
flashlight surveillance.” (Mot. Ex.C at2). That same day, Judge Nathan directed
the Government to confer with MDC legal counsel and provide
Case 21-770, Document 73, 05/27/2021, 3109708, Page8 of 24
“unpersuaded” by Maxwell’s argument “that the conditions of her confinement are
uniquely onerous, interfere with her ability to participate
Case 21-770, Document 73, 05/27/2021, 3109708, Page? of 24
13. Second, on December 8, 2020, Maxwell renewed her request for
bail, presenting a revised bail package with additional financial restricti
Case 21-770, Document 73, 05/27/2021, 3109708, Page6 of 24
things, Judge Nathan emphasized Maxwell’s “substantial international ties,”
including “multiple foreign citizenships,” “familial and persona
Case 21-770, Document 73, 05/27/2021, 3109708, Page4 of 24
sexual abuse of multiple minor victims by Jeffrey Epstein between approximately
1994 and 1997.2 (Ind. § 1). During that period, Maxwell play
Case 21-770, Document 73, 05/27/2021, 3109708, Paged of 24
10. As the Government has explained in oral and written proffers,
the allegations in the Indictment are supported by the detailed, credible
CaSest:20-cr/008BG AGA B6cumMeEnt 2222 FileqOs/H7/PagPage 22st 3
LAW OFFICES OF BOBBI C. STERNHEIA\
Form listed “psych alerts,” which are baseless, and “broad publicity,” which is accurate and
concer
CaSest:20-cr/008aG AGA B6eumMeEnt 2222 FileqOs/H7/Pag Page Bast 3
LAW OFFICES OF BOBBI C. STERNHEIA\
In the face of the Epstein’s death on the BOP’s watch, the MDC would not risk a repeat
of the deba
Case 21-770, Document 70-2, 05/17/2021, 3102450, Page17 of 20
Exhibit E
Doc. 272
Ghislaine Maxwell’s Reply regarding conditions at
Metropolitan Detention Center
May 7, 2021
DOJ-OGR-00001437
CaSesb:20-cr-00880+A0Nt BOcuMeEnt BRE 2 Filed0O4/29/PagPag ena 4
EXHIBIT B
DOJ-OGR-00001433
CaSest:20-cr/00BatAGNt B6eumMeEnt 2262 Filed0w4/20/Prg Page Rast 4
LAW OFFICES OF BOBBI C. STERNHEIA\
The MDC routinely places inmates in the SHU if they have engaged in physical
altercation with oth
CaSede201 er WD IZ0cAdhtn DEbamentl 7820 AAiled OBADA) 2Radragef 2 Of 2
can arise in high-profile cases. The MDC has determined that these factors necessitate more
frequent safety and security checks
Case 21-770, Document 70-2, 05/17/2021, 3102450, Page9 of 20
Exhibit C
Doc. 256
Ghislaine Maxwell letter regarding conditions at Metropolitan
Detention Center
April 29, 2021
DOJ-OGR-00001429
Case 21-770, Document 70-2, 05/17/2021, 3102450, Page2 of 20
Appendix*
App. 86 Second Circuit Court Order
April 27, 2021 ......ccccccccccsceessccessceessceeesecessseeessecetteeenseeee A
Doc. 282 Lo
Case 21-770, Document 70-2, 05/17/2021, 3102450, Page6 of 20
Exhibit B
Doc. 282
Lower Court Order
May 14, 2021
DOJ-OGR-00001426
Case 21-770, Document 70-2, 05/17/2021, 3102450, Page4 of 20
Exhibit A
App. 86
Second Circuit Court Order
April 27, 2021
DOJ-OGR-00001424
Case 21-770, Document 70-2, 05/17/2021, 3102450, Page3 of 20
CERTIFICATE OF SERVICE
I CERTIFY that a true and correct copy of the foregoing was e-filed
this 17th day of May, 2021.
/s/ David Oscar M
Case 21-770, Document 70-1, 05/17/2021, 3102450, Page14 of 14
CERTIFICATE OF COMPLIANCE
I CERTIFY that this petition complies with the type-volume
limitation of FED. R. App. P. 27. According to Micro
Case 21-770, Document 70-1, 05/17/2021, 3102450, Page12 of 14
something.” See transcript of sentencing hearing, United States v.
Tiffany Days, April 29, 2021, which can be _ accessed at:
https://tiny
Case 21-770, Document 70-1, 05/17/2021, 3102450, Page11 of 14
the evidence and a hearing so that we may demonstrate our other claims.
These requests have been denied. In any event, the government doe
Case 21-770, Document 70-1, 05/17/2021, 3102450, Page13 of 14
order the district court to conduct a hearing on the conditions of her
confinement so that the defense can make the appropriate showing.
Case 21-770, Document 70-1, 05/17/2021, 3102450, Page10 of 14
gave to Ms. Maxwell contrary to MDC Brooklyn’s legal visit procedures
were confiscated by staff...” Doc. 259. Ms. Maxwell’s lawyers showe
Case 21-770, Document 70-1, 05/17/2021, 3102450, Page9 of 14
actually told to clean with our own hands. It was humiliating. Floating,
dead water bugs, mice, chunks of defecation coming out of the pip
Case 21-770, Document 70-1, 05/17/2021, 3102450, Page8 of 14
be singled out in this way because she is alone, the nature of the charges,
and that this is high profile case. But those reasons, individ
Case 21-770, Document 70-1, 05/17/2021, 3102450, Page? of 14
2. Government misrepresentation to this Court during oral
argument when asked if shining lights in Ms. Maxwell’s face every fifteen
minute
Case 21-770, Document 70-1, 05/17/2021, 3102450, Paged of 14
going through her attorney-client materials; and (6) can’t search, print,
highlight, or sort the discovery because the “computer” she was
Case 21-770, Document 70-1, 05/17/2021, 3102450, Page6 of 14
letter to district court) (“MDC legal counsel has informed the government
that the defendant cannot be provided with an eye mask.”). So Ms
Caseat2 O4cir-003B0AuTKEnDoCuate h® LW? 1 FAGaO67RageP aged 40f 5
LAW OFFICES OF BOBBI C. STERNHEIA\
taken seriously,” and just like the majority of complaints filed by inmates, the facility refuses
Caseat2 O4cr-003B0ATHEnDo Cunt mh’ LW? 1 Fea O2967RageBage SHf 5
LAW OFFICES OF BOBBI C. STERNHEIA\
The Court’s request for updates concerning Ms. Maxwell’s conditions of confinement
does little to i
Case 21-770, Document 66, 04/27/2021, 3087699, Page‘ of 1
United States Court of Appeals for the Second Circuit
Thurgood Marshall U.S. Courthouse
40 Foley Square
New York, NY 10007
DEBRA ANN LIVINGS
Caseat2 O4cr-003B0AuTKEnDo Cunt hPL? 1 FAGaO67RAgePagd 20f 5
LAW OFFICES OF BOBBI C. STERNHEIA\
regularly, I challenge the government to identify anyone that would risk their health by drinking
the t
Caseat204cr-003B0-AUNenDoCcuite MP LOZ 1 FueaO@67RagePage BOf 5
LAW OFFICES OF BOBBI C. STERNHEIA
212-243-1100 © Main 33 West 19th Street - 4th Floor
917-306-6666 ® Cell New York, New York 10011
888
CaStas204e-003B0AUNENDoCuade hP 202 1 FueaMeBS5RageP age Z0Of 8
LAW OFFICES OF BOBBI C. STERNHEIA\
government in person to confer on a briefing schedule for supplemental pretrial motions, as well
as
Case 21-770, Document 57, 04/19/2021, 3080288, Page25 of 30
EXHIBIT P
DOJ-OGR-00001397
CaStas204c7-O03B0AWwNENDoCuade hP 202 1 FReACRBS5RageP age SOf 8
LAW OFFICES OF BOBBI C. STERNHEIA\
years and elected to commence prosecution of Ms. Maxwell in the throes of the pandemic. A//
counsel
CaStas201c7-003B0AuWNENDoCuade hP 202 1 FReaMRBS5RagePageé 8Of 8
LAW OFFICES OF BOBBI C. STERNHEIA\
Conclusion
We raise these issues in advance of the arraignment scheduled for April 23" in support o
CaStas201c-003B0AuNENDoCuade h 202 1 FHeaCRBS5RageP ages 40f 8
LAW OFFICES OF BOBBI C. STERNHEIA\
The defense has tried to streamline its review of the discovery even before the filing of
superseding
CaStas201c-003B0AWNENDo Cua hP 202 1 FueadesS5Rager age 30f 8
LAW OFFICES OF BOBBI C. STERNHEIA\
materials in the MDC. Although defense counsel have not yet been able to fully review the
materials, w
CaStas201c7-003B0AWNENDoCuade hP 202 1 FueaGesS5Rager age 20f 8
LAW OFFICES OF BOBBI C. STERNHEIA\
investigation in 2007 (see Dkt. 199 at 1-2), long before commencing this prosecution against Ms.
Max
Case 21-770, Document 57, 04/19/2021, 3080288, Page15 of 30
CERTIFICATE OF COMPLIANCE
I CERTIFY that this petition complies with the type-volume
limitation of FED. R. APP. P. 27. According to Microso
Case 21-770, Document 57, 04/19/2021, 3080288, Page16 of 30
EXHIBIT O
DOJ-OGR-00001388
Case 21-770, Document 57, 04/19/2021, 3080288, Page13 of 30
CONCLUSION
Ms. Maxwell should be released. The allegations against her are
weak, she is not a risk of flight, and her appearance at trial
Case 21-770, Document 57, 04/19/2021, 3080288, Page14 of 30
where she can demonstrate that her conditions of confinement make
preparing for trial impossible. There must be an adversarial hearing
wher
Case 21-770, Document 57, 04/19/2021, 3080288, Page12 of 30
Gov tEx. (April 6, 2021 letter, n.2). But as Ms. Maxwell explained, the
Government’s narrative is total fiction — the unsanitary conditions