EFTA00013222.pdf

Type: pdf
Source set: data-set-8

Extracted text

COHEN & GRESSER LLP
October 1, 2020
BY EMAIL
Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear
We write once again to express our dissatisfaction that the government still has not
provided a complete set of readable discovery materials to Ms. Maxwell in the MDC. We have
now had several phone calls and emails to discuss the problems with the discovery, but the
problems still are not fixed. It is now over five weeks since the August 21 discovery deadline set
by the court and the government still has not met its discovery obligations. That is simply not
acceptable.
In our previous letter, dated September 21, 2020, we outlined for you the numerous
problems that Ms. Maxwell had been having with unreadable discovery files since she first began
receiving the government's productions in the MDC in August 2020. This was a continuation of
the same problem we identified for you in our letter, dated August 27, 2020, when we requested a
new set of the discovery materials that were fully readable.
On September 22, 2020, we had a conference call to discuss these issues. On that call, you
stated that you were trying to address the readability problems, but that in the meantime, defense
counsel could, among other things, create a laptop computer with a full copy of the discovery
saved locally that defense counsel could bring to the MDC so that Ms. Maxwell could use it to
review the unreadable discovery. You also notified us that there were approximately 40,000 non-
nude photographs and images, and thousands of nude or partially nude images, which had been
seized from Jeffrey Epstein's residences in New York and the Virgin Islands pursuant to search
warrants, and which you had referenced in your August 21, 2020 production cover letter. You
further advised that you were in the process of scanning those images so that you could produce
any documents not marked Highly Confidential in electronic format. Finally, in response to our
request that Ms. Max…

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