EFTA00022514.pdf

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pdf

Source set

data-set-8

Original source

Extracted text

Case 1:20-cr-00330-AJN Document 260 Filed 04/30/21 Page 1 of 2 
COHEN & GRESSER LLP 
BY ECF 
The Honorable Alison J. Nathan 
United States District Court 
Southern District of New York 
United States Courthouse 
USDC SONY 
DOCUMENT 
ELECTRONICALLY FILED 
DOC 0: 
DATE FILED: 5/3/21 
April 30, 2021 
9D OltOUID. 
ALIION I. mama 
I 
Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) 
Dear Judge Nathan: 
SOO Thad Avenue 
New Yolk. NY 10022 
♦1 212 957 7600 phono 
www cohongartav corn 
Counsel for the MDC may 
submit any objection to 
the Defendant's request by 
May 4, 2021. 
SO ORDERED. 
We write to respectfully request the Court to issue an order to the MDC directing it to 
accept two hard drives from defense counsel that contain the non-Highly Confidential discovery in 
this case for Ms. Maxwell's use at the MDC. 
In an effort to facilitate Ms. Maxwell's review of the discovery, defense counsel have 
created a master set of two hard drives that contain a complete set of the discovery produced by 
the government so far, excluding the materials marked Highly Confidential, which Ms. Maxwell is 
not permitted to possess in the MDC pursuant to the terms of the Protective Order. The master 
drives are easier to use than her existing hard drives because they collect all of the material in one 
place and organize the documents in a more user-friendly format. For example, the November 18, 
2020 production containing roughly 2.2 million pages was produced in load file format, which 
contains images of individual pages of documents in native file format, image file format, and 
other formats. The hard drives organize these files by document, as opposed to by page, and 
eliminate duplicative file formats so that Ms. Maxwell will not have to add countless hours to her 
review. 
Defense counsel would like to send these hard drives to Ms. Maxwell for her to use in the 
MDC. We were informed by the MDC Legal Department that they are only permitted to accept 
hard drives that are …

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