EFTA00021015.pdf

Type

pdf

Source set

data-set-8

Original source

Extracted text

LAW OFFICES OF BOBBI C.STERNHEIM 
212-243-1100 • Moln 
917-306-6666 • Cell 
888-587-4737 • Fax 
Honorable Alison J. Nathan 
United States District Judge 
United States Courthouse 
40 Foley Square 
New York, NY 10007 
Dear Judge Nathan: 
33 West 19th Street - 4th Floor 
New York, New York 10011 
[email protected] 
February I, 2021 
Re. United States v. Ghislaine Maxwell 
20 Cr. 330 (MN) 
By letter to the Court, dated January 25, 2021 (Dkt.117 at 2-3), the MDC raised objection 
to the Court's order, unopposed by the government, directing the MDC to permit Ms. Maxwell to 
use on a laptop computer on weekends and holidays. (Dkt. 116 at 2). The MDC has failed to 
state a valid or compelling reason for opposing the Court's directive. 
The MDC does not identify any valid reason why Ms. Maxwell cannot have access to the 
laptop computer on weekends and holidays. The MDC does not argue, for example, that access 
to the laptop cannot be provided because of issues related to safety or security, staffing, or (to 
quote the government) the need to "manag[e] its inmate population." Instead, in opposition to 
the Court's order, the MDC repeats its stock response: Ms. Maxwell has received significant 
amount of time to review her discovery and has more contact with counsel than any other MDC 
inmate is allotted. The MDC's fixation on the relative time Ms. Maxwell has been given to 
review discovery is totally misguided. The government has produced millions of pages of 
discovery. Ms. Maxwell has the right to review all of them in order to prepare her defense for 
trial. To do that, she needs access to the laptop for as much time as possible, including the 
weekends and holidays because the prison computers are incapable of reading the millions of 
discovery documents. Ms. Maxwell loses 10 or more hours per week due to delay in receiving 
the laptop, problems caused by the MDC computer, and inability to access the computer during 
morning and afternoon counts on the weekends. Comp…

Open in the interactive archive →