EFTA00010196.pdf

Type

pdf

Source set

data-set-8

Original source

Extracted text

Case 1:20-cr-00330-AJN Document 78 Filed 12/02/20 Page 1 of 2 
U.S. Department of Justice 
United States Attorney 
Southern District of New York 
The Silvio J. Mono Building 
One Saint Andrew's Plaza 
New York. New York 10007 
December 1, 2020 
BY ECF 
The Honorable Alison J. Nathan 
United States District Court 
Southern District of New York 
United States Courthouse 
40 Foley Square 
New York, New York 10007 
Re: 
United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) 
Dear Judge Nathan: 
USDC SONY 
DOCUMENT 
ELECTRONICALLY FILED 
DOC 0: 
DATE FILED: 1212120
The parties jointly submit this letter in response to the Court's November 24, 2020 order 
directing the parties to meet and confer regarding the defendant's request that the warden of the 
Metropolitan Detention Center ("MDC") report directly to the Court and counsel on the 
defendant's conditions of 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 respective positions 
follow. 
The Government respectfully submits that the Court should allow MDC legal counsel to 
respond directly in writing to the Court and defense counsel regarding the concerns defense 
counsel has raised relating to the defendant's conditions of confinement. The Government 
understands that MDC legal counsel is prepared to submit a letter by this Friday, December 4, 
2020. Such a letter is the appropriate next step at this time, as it will allow the Court to hear 
directly from MDC legal counsel who can address the defendant's conditions of confinement. The 
letter will allow the Court…

Open in the interactive archive →