EFTA00015972.pdf

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Source set: data-set-8
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Subject: RE: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera 
Date: Mon, 21 Dec 2020 21:55:26 +0000 
Yes, I highlighted the huge volume of discovery for Maxwell when I spoke with 
this morning. That volume was a 
significant driver in our team's decision to request that she receive so much time to review her discovery. Based on my 
read of the transcript from this morning's Rivera conference, it sounds like Rivera is not even using all the time he has 
now. By contrast, my understanding is that Maxwell is using up the full time she has been given. 
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Subject: RE: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera 
I'd also look into potential differences in the volume of discovery. No idea what your case entails, MEI but in Maxwell 
we have produced truly enormous volumes of material (we seized 60 some devices during the investigation, for example, 
in addition to an entire FBI file from the prior Florida investigation...) that may explain some of this. 
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Subject: RE: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera 
Thanks, 
Can you keep me posted on what we think will be the substance of the draft declaration when you know 
(that is, before we are submitting anything on 12/31)? And how much of this is attributable to differences between MCC 
and MDC, as well as specific differences in their housing situations? 
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EFTA00015972…
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