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981 KB

Extraction Summary

3
People
5
Organizations
3
Locations
2
Events
2
Relationships
4
Quotes

Document Information

Type: Legal letter / court filing
File Size: 981 KB
Summary

A letter from the U.S. Attorney's Office to Judge Alison J. Nathan dated February 1, 2021, regarding the conditions of Ghislaine Maxwell's confinement at the MDC. The Government addresses a dispute over Maxwell's access to a laptop for reviewing over two million pages of discovery materials on weekends and holidays. While the Government does not object to the access, they defer to MDC management protocols, noting that Maxwell already receives more review time (13 hours/day, 7 days/week) than any other inmate.

People (3)

Name Role Context
Alison J. Nathan Judge
Recipient of the letter; United States District Court Judge presiding over the case.
Ghislaine Maxwell Defendant
Subject of the case (United States v. Ghislaine Maxwell); requesting laptop access for discovery review.
MDC Legal Counsel Legal Representative
Representing the Metropolitan Detention Center; requested the court vacate a previous order.

Organizations (5)

Name Type Context
U.S. Department of Justice
Header organization.
United States Attorney Southern District of New York
Sender of the letter.
Metropolitan Detention Center (MDC)
Facility where the defendant is held and which manages her computer access.
Bureau of Prisons (BOP)
Mentioned in relation to the desktop computer provided to the defendant.
United States District Court
Court handling the case.

Timeline (2 events)

August 2020
Government made its first discovery production.
MDC
Government Ghislaine Maxwell
November 18, 2020
Government hand delivered a laptop to the MDC for the defendant's exclusive use.
MDC
Government MDC Ghislaine Maxwell

Locations (3)

Location Context
Office address of the US Attorney.
Address of the Court/Judge Nathan.
Location of defendant's confinement.

Relationships (2)

Ghislaine Maxwell Legal Adversaries United States Government
Case title: United States v. Ghislaine Maxwell
MDC Custodian/Inmate Ghislaine Maxwell
Maxwell is an inmate at MDC; MDC manages her laptop access/schedule.

Key Quotes (4)

"The Government will continue to defer to the MDC here, particularly because the defendant has had ample access to discovery even without laptop access on weekends and holidays."
Source
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Quote #1
"Given the volume of discovery in this case, which totals more than two million pages..."
Source
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Quote #2
"...the defendant has received, and continues to receive more time to review her discovery than any other inmate at the MDC."
Source
DOJ-OGR-00001355.jpg
Quote #3
"In particular, the MDC permits the defendant to review discovery thirteen hours per day, seven days per week."
Source
DOJ-OGR-00001355.jpg
Quote #4

Full Extracted Text

Complete text extracted from the document (2,925 characters)

Case 1:20-cr-00330-AJN Document 129 Filed 02/01/21 Page 1 of 2
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew’s Plaza
New York, New York 10007
February 1, 2021
BY ECF
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
United States Courthouse
40 Foley Square
New York, New York 10007
Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan:
The Government respectfully submits this letter in response to the Court’s January 25, 2021
order allowing the parties to respond to a letter from legal counsel at the Metropolitan Detention
Center (“MDC”) also dated January 25, 2021. (Dkt. No. 117). In particular, MDC legal counsel
asks the Court to vacate its January 15, 2021 order directing the MDC to permit the defendant to
use a laptop to review discovery on weekends and holidays. While the Government has no
objection to the defendant’s request for additional laptop access, the Government also generally
defers to the MDC regarding how it manages its inmate population. The Government will continue
to defer to the MDC here, particularly because the defendant has had ample access to discovery
even without laptop access on weekends and holidays.
Given the volume of discovery in this case, which totals more than two million pages, the
Government and the MDC have both made significant efforts to ensure that the defendant has
extensive access to her discovery materials. Since the Government made its first discovery
production in August 2020, the defendant has had exclusive access to a BOP desktop computer in
the MDC on which to review her discovery. When the defendant complained of technical issues
reviewing portions of her discovery on that desktop computer, the Government produced
reformatted copies of discovery materials and instructions regarding how to open particular files.
Because the defendant continued to complain that she was unable to review certain discovery files
on the desktop computer, the Government agreed to provide a laptop for the defendant to use in
her review of discovery. On November 18, 2020, the Government hand delivered the laptop to
the MDC for the defendant’s exclusive use.
As the Court is aware, the defendant has received, and continues to receive more time to
review her discovery than any other inmate at the MDC. In particular, the MDC permits the
defendant to review discovery thirteen hours per day, seven days per week. On weekdays, the
MDC permits the defendant to use the laptop during her thirteen hours of daily review time. On
weekends and holidays, the MDC would ordinarily only allow the defendant to use the BOP
desktop computer, which provides access to much of the discovery material. While, as noted
above, the Government has no particular objection to the defendant’s request for weekend access
DOJ-OGR-00001355

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