EFTA00072486Set 9
2020-11-2322p6,899w
Over the past three months, the
Government has had multiple conversations with MDC legal counsel regarding the defendant's
conditions of confinement. This update is based on information provided ... Government by
MDC legal during those conversations.
Last week, a staff member who was assigned to work in the area of the MDC where the
defendant is housed tested positive ... noted above, over the past three months, the Government has repeatedly communicated
both with MDC legal counsel and defense counsel regarding the defendant's conditions of
confinement. Whenever the defense
https://www.justice.gov/epstein/files/DataSet%209/EFTA00072486.pdf
EFTA00027268Set 8
2020-11-2322p6,962w
Over the past three months, the
Government has had multiple conversations with MDC legal counsel regarding the defendant's
conditions of confinement. This update is based on information provided ... Government by
MDC legal during those conversations.
Last week, a staff member who was assigned to work in the area of the MDC where the
defendant is housed tested positive ... noted above, over the past three months, the Government has repeatedly communicated
both with MDC legal counsel and defense counsel regarding the defendant's conditions of
confinement. Whenever the defense
https://www.justice.gov/epstein/files/DataSet%208/EFTA00027268.pdf
EFTA00086246Set 9
2021-04-269p3,088w
York, N,
DATE FILED: 427/21
888-587-4737 • Fax bC@Sli
April 26, 2021
MDC legal counsel is hereby
Honorable Alison J. Nathan ORDERED to show cause by April ... States Courthouse letter to the Defendant's counsel ought
40 Foley Square not issue. MDC legal counsel shall
New York, NY 10007 either docket it on ECF or email ... that her legal papers were confiscated.
Later that day, I received an email from MDC legal counsel, which
stated:
It has been brought to my attention by the staff
https://www.justice.gov/epstein/files/DataSet%209/EFTA00086246.pdf
EFTA00081395Set 9
2021-04-269p3,081w
York, Ni DATE FILED: 4127/21
888-587-4737 • Fax bC@SN
April 26, 2021
MDC legal counsel is hereby
ORDERED to show cause by April 28,
Honorable Alison J. Nathan ... States Courthouse letter to the Defendant's counsel ought
40 Foley Square not issue. MDC legal counsel shall
New York, NY 10007 either docket it on ECF or email ... legal papers were confiscated.
Later that day, I received an email from Sophia Papapetru, MDC legal counsel, which
stated:
It has been brought to my attention by the staffofMDC Brooklyn
https://www.justice.gov/epstein/files/DataSet%209/EFTA00081395.pdf
EFTA00097874Set 9
2021-08-183p1,170w
resolved between defense counsel and the MDC.
However, on August 6, 2021, MDC Legal sent counsel an email stating that starting Monday
(August 9th) we could no longer use defense ... MDC. When questioned why the platform was
being changed from WebEx to Zoom, MDC Legal stated the VTC platform was changed due to
complaints made by Ms. Maxwell. Upon information ... with dealing with Ms. Maxwell's electronics issues.
By email dated August 12ih to MDC Legal, with government counsel copied, I reported
that this purported breach severely impacts confidential privileged
https://www.justice.gov/epstein/files/DataSet%209/EFTA00097874.pdf
EFTA00097871Set 9
2021-08-183p1,171w
resolved between defense counsel and the MDC.
However, on August 6, 2021, MDC Legal sent counsel an email stating that starting Monday
(August 9th) we could no longer use defense ... MDC. When questioned why the platform was
being changed from WebEx to Zoom, MDC Legal stated the VTC platform was changed due to
complaints made by Ms. Maxwell. Upon information ... with dealing with Ms. Maxwell's electronics issues.
By email dated August 12ih to MDC Legal, with government counsel copied, I reported
that this purported breach severely impacts confidential privileged
https://www.justice.gov/epstein/files/DataSet%209/EFTA00097871.pdf
EFTA00040660Set 9
2021-08-183p1,173w
resolved between defense counsel and the MDC.
However, on August 6, 2021, MDC Legal sent counsel an email stating that starting Monday
(August 9th) we could no longer use defense ... MDC. When questioned why the platform was
being changed from WebEx to Zoom, MDC Legal stated the VTC platform was changed due to
complaints made by Ms. Maxwell. Upon information ... with dealing with Ms. Maxwell's electronics issues.
By email dated August 12ih to MDC Legal, with government counsel copied, I reported
that this purported breach severely impacts confidential privileged
https://www.justice.gov/epstein/files/DataSet%209/EFTA00040660.pdf
EFTA00072464Set 9
2020-11-2310p3,556w
Over the past three months, the
Government has had multiple conversations with MDC legal counsel regarding the defendant's
conditions of confinement. This update is based on information provided ... Government by
MDC legal during those conversations.
Last week, a staff member who was assigned to work in the area of the MDC where the
defendant is housed tested positive ... noted above, over the past three months, the Government has repeatedly communicated
both with MDC legal counsel and defense counsel regarding the defendant's conditions of
confinement. Whenever the defense
https://www.justice.gov/epstein/files/DataSet%209/EFTA00072464.pdf
EFTA00072474Set 9
2020-12-0112p3,345w
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 ... 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 ... 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
https://www.justice.gov/epstein/files/DataSet%209/EFTA00072474.pdf
EFTA00089154Set 9
2020-12-0834p11,257w
recently implemented lockdown at the MDC, visitation is not
currently available, but MDC legal counsel is arranging for the defendant to receive a VTC call
with legal counsel three hours ... counsel. The Government will continue to work with MDC
9 The Government understands from MDC legal counsel that the defendant has access to the
laptop thirteen hours per day during ... inmates in protective custody. Additionally, psychology and medical staff check on the
defendant daily, MDC legal staff are highly attuned to any complaints the defendant has raised,
and following initial
https://www.justice.gov/epstein/files/DataSet%209/EFTA00089154.pdf
EFTA00096519Set 9
2021-05-1734p6,320w
Document 89-1, 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 ... Court's question whether the defendant can be provided with "appropriate eye
covering," MDC legal counsel has informed the Government that the defendant cannot be provided
with an eye mask
https://www.justice.gov/epstein/files/DataSet%209/EFTA00096519.pdf
EFTA00079701Set 9
2020-12-012p686w
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 ... 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 ... 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
https://www.justice.gov/epstein/files/DataSet%209/EFTA00079701.pdf
EFTA00010196Set 8
2020-12-012p693w
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 ... 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 ... 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
https://www.justice.gov/epstein/files/DataSet%208/EFTA00010196.pdf
EFTA00105614Set 9
2021-04-064p1,650w
This update is based on information
provided to the Government by MDC legal counsel regarding the conditions of the defendant's
confinement over the last two months.
The defendant continues ... February 2021 regarding the defendant's food, water, and physical wellbeing. In response, MDC
legal counsel informed the Government that the defendant's meals arrive in containers that are
both ... defendant's cell did not clear after being run for several seconds. MDC legal
counsel emphasized that MDC staff, including the legal staff, drink the same tap water from
https://www.justice.gov/epstein/files/DataSet%209/EFTA00105614.pdf