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Case 21-770, Document 3-2, 03/24/2021, 3065978, Page16 of 25 12/04/2020 | 85 | LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Christian R. Everdell dated December 4, 2020 re: Briefing Schedule (Everdell, Christian) (Entered: 12/04/2020) 12/04/2020 LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Christian R. Everdell dated 11/25/2020 re: Sealing (Everdell, Christian) (Entered: 12/04/2020) 12/04/2020 LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Christian R. Everdell dated 11/30/2020 re: Sealing (Everdell, Christian) (Entered: 12/04/2020) 12/07/2020 | 88 | LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Sophia Papapetru and John Wallace dated 12/4/20 re: This letter is written in response to your order dated December 2, 2020, concerning Ghislaine Maxwell, Reg. 02879—509., an inmate currently confined at the Metropolitan Detention center in Brooklyn, New York. You expressed various concerns regarding Ms. Maxwells confinement and well-being. (jw) (Entered: 12/07/2020) 12/07/2020 ORDER as to Ghislaine Maxwell re: 85 Letter filed by Ghislaine Maxwell. The Court is in receipt of the Defendant's December 4, 2020 letter, Dkt. No. 85, and hereby sets the following schedule: The Defendants submission is due December 8, 2020; The Government's response is due December 16, 2020; The Defendant's reply is due December 18, 2020. After reviewing these submissions, the Court will determine whether a hearing on the renewed bail motion is necessary. The Court grants the Defendants request that the Government shall file its submission under seal with proposed redactions. Any objections to proposed redactions are due within 24 hours after any brief has been filed. Finally, the Defendant is granted leave to file a motion not to exceed 40 pages. The Governments response shall also be limited to 40 pages. The Defendant's reply shall not exceed 10 pages ( Defendant submission due by 12/8/2020., Defendant Replies due by 12/18/2020., Government Responses due by 12/16/2020) (Signed by Judge Alison J. Nathan on 12/7/20)(jw) (Entered: 12/07/2020) 12/07/2020 ENDORSED LETTER as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from Mark S. Cohen and Christian R. Everdell dated 11/25/20 re: On behalf of my client, Ghislaine Maxwell, we plan to file a Renewed Motion for Release on Bail (the "Motion") and respectfully request an in camera conference, with all counsel present, to address the appropriate procedures for the filing and consideration of the Motion. For the reasons explained below, we intend to request, pursuant to Fed. R. Crim. P. 49.1(d), that the Court permit the filing of portions of the Motion and certain supporting materials under seal and require that any responsive materials be filed under seal... ENDORSEMENT: The Court sees no basis for the sealing of this letter. On or before December 2, 2020, Defendant shall justify why this letter should be sealed (or redacted). Alternatively, the Defendant may file the letter on the public docket by that date. The Court will take no action on the request pending resolution of the initial sealing question. The Defendant's letter and this memorandum endorsement will be temporarily sealed pending resolution of the sealing request. (Signed by Judge Alison J. Nathan on 11/25/20)qGw) (Entered: 12/07/2020) 12/07/2020 LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Bobbi C. Sternheim dated 12/07/2020 re: Response to MDC Report to Court re: conditions (Sternheim, Bobbi) (Entered: 12/07/2020) 12/08/2020 ORDER as to Ghislaine Maxwell: On December 4, 2020, the Court received a letter from MDC legal counsel responding to the concerns that the Defendant raised in her November 24, 2020 letter. See Dkt. Nos. 75, 88; see also Dkt. No. 78. The Defendant responded to the MDC legal counsel's letter on December 7, 2020, reiterating her request that the Court summon Warden Heriberto Tellez to personally respond to questions from the Court regarding the Defendant's conditions of confinement. See Dkt. No. 91. Having carefully reviewed the parties' submissions, along with the MDC legal counsel's December 4, 2020 letter, the Court DENIES the Defendant's request to summon the Warden to personally appear and respond to questions. This resolves Dkt. No. 75. Notwithstanding this, as originally provided in Dkt. No. 49, the Government shall continue to submit written status updates detailing any material changes to the conditions of Ms. Maxwell's confinement, with particular emphasis on her access to legal materials, including legal mail and email, and her ability to communicate with defense counsel. The updates shall also include information on the frequency of searches of the Defendant. The Court hereby ORDERS the Government to submit these written updates every 60 days. Furthermore, the Government shall take all DOJ-OGR- 00000892