EFTA00013225.pdf

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pdf

Source set

data-set-8

Original source

Extracted text

COHEN & GRESSER LLP 
September 21, 2020 
BY EMAIL 
Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) 
Dear 
We write to address three issues. First, we write to express once again our dissatisfaction 
with the incomplete and inadequate production of discovery to Ms. Maxwell in the MDC, and to 
demand that the government find an immediate solution that will permit Ms. Maxwell to review 
all of the discovery materials produced to date. Second, we write to request that the government 
set up a time at the earliest convenience when Ms. Maxwell and defense counsel can review the 
documents marked as "Highly Confidential" in the discovery materials. Third, we write to 
register our objection to the onerous conditions of confinement to which Ms. Maxwell is 
subjected, which are entirely unique to Ms. Maxwell. We request that the government intercede 
directly with the BOP to improve these conditions, as set forth below. 
1. Ms. Maxwell Still Cannot Access All of the Discovery 
One full month has now passed since August 21, 2020, the date the government 
represented to the Court that it would complete production of the initial group of discovery 
materials, and Ms. Maxwell still cannot read a substantial portion of the discovery produced to 
date. The government further represented to the Court at the initial appearance on July 14, 2020 
that this initial group of discovery materials represents "the core of the case" against Ms. Maxwell. 
(Tr. at 12, line 11). Ms. Maxwell has therefore been denied full access to the most critical 
evidence in this case for a month. This is unacceptable and inconsistent with the government's 
obligations and its representations to Judge Nathan; this must be fixed immediately. 
The government represented to the Court at the initial appearance that it was "prepared to 
make a substantial production of discovery" as soon as the protective order was entered. (Tr. 12-
13). However, the government was clearly not prepared to produce discove…

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