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837 KB

Extraction Summary

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

Document Information

Type: Legal correspondence / court filing
File Size: 837 KB
Summary

This document is a letter from attorney Christian R. Everdell to Judge Alison J. Nathan, dated January 14, 2021, requesting a court order to allow Ghislaine Maxwell access to a government-provided laptop on weekends and holidays to review discovery materials. The letter notes that the current prison computer lacks necessary software, the volume of discovery is massive ahead of the July 12, 2021 trial, and the government does not object to this request. It also highlights that Maxwell previously had daily access during a quarantine period in late 2020.

People (4)

Name Role Context
Christian R. Everdell Attorney
Author of the letter, representing Ghislaine Maxwell, partner at Cohen & Gresser LLP.
Alison J. Nathan Judge
Recipient of the letter, presiding over United States v. Ghislaine Maxwell.
Ghislaine Maxwell Defendant
Subject of the request regarding access to a laptop for discovery review.
MDC Staff Member Staff
Unnamed staff member who tested positive for COVID, causing Maxwell's quarantine.

Organizations (5)

Name Type Context
Cohen & Gresser LLP
Law firm representing Ghislaine Maxwell.
United States District Court Southern District of New York
Court where the case is being heard.
Bureau of Prisons
Agency controlling Maxwell's detention conditions.
MDC
Metropolitan Detention Center, the facility where Maxwell is held.
The Government
Prosecution team, mentioned as having no objection to the request.

Timeline (2 events)

2021-07-12
Scheduled Trial Date for United States v. Ghislaine Maxwell.
SDNY
November-December 2020
14-day quarantine period for Ghislaine Maxwell due to COVID contact.
MDC Isolation Cell
Ghislaine Maxwell MDC Staff

Locations (4)

Location Context
Address of Cohen & Gresser LLP.
Address of the United States Courthouse.
MDC
Prison facility where Maxwell is detained.
Location within MDC where Maxwell was quarantined in Nov-Dec 2020.

Relationships (2)

Christian R. Everdell Attorney-Client Ghislaine Maxwell
Letter states 'We write on behalf of our client, Ghislaine Maxwell'
Letterhead and email address

Key Quotes (4)

"We write on behalf of our client, Ghislaine Maxwell, to respectfully request that the Court order the Bureau of Prisons to give Ms. Maxwell access to the laptop computer provided by the government so that she can review discovery on weekends and holidays."
Source
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Quote #1
"If Ms. Maxwell is to have any hope of reviewing the millions of documents produced in discovery so that she can properly prepare her defense by the July 12, 2021 trial date, she must have access to the laptop every day, including weekends and holidays."
Source
DOJ-OGR-00002270(1).jpg
Quote #2
"Defense counsel has raised this issue with the government and it has no objection to Ms. Maxwell having access to the laptop seven days a week."
Source
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Quote #3
"There is no principled justification for this restriction."
Source
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Quote #4

Full Extracted Text

Complete text extracted from the document (2,534 characters)

Case 1:20-cr-00330-AJN Document 115 Filed 01/15/21 Page 1 of 2
C&G COHEN & GRESSER LLP
800 Third Avenue
New York, NY 10022
+1 212 957 7600 phone
[Stamp: USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC #: DATE FILED: 1/15/21]
Christian R. Everdell
+1 (212) 957-7600
ceverdell@cohengresser.com
January 14, 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, NY 10007
Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan:
We write on behalf of our client, Ghislaine Maxwell, to respectfully request that the Court order the Bureau of Prisons to give Ms. Maxwell access to the laptop computer provided by the government so that she can review discovery on weekends and holidays.
At the request of defense counsel, the government provided Ms. Maxwell with a laptop computer to review the voluminous discovery, which was produced on a series of external hard drives. Currently, Ms. Maxwell is given access to the laptop only on weekdays. On weekends and holidays, Ms. Maxwell must use the prison computer on her floor to review discovery. However, the prison computer is not equipped with the software necessary to read large portions of the discovery recently produced by the government. As a result, Ms. Maxwell loses several days of review time every weekend and every holiday because she does not have access to the laptop. If Ms. Maxwell is to have any hope of reviewing the millions of documents produced in discovery so that she can properly prepare her defense by the July 12, 2021 trial date, she must have access to the laptop every day, including weekends and holidays.
Defense counsel has raised this issue with the government and it has no objection to Ms. Maxwell having access to the laptop seven days a week. At the request of defense counsel, the government has contacted officials at the MDC on several occasions in the past few weeks to request that they lift this restriction, but without success.
There is no principled justification for this restriction. Ms. Maxwell was given access to the laptop every day (including weekends and the Thanksgiving holiday) for the entire 14-day period that she was quarantined in her isolation cell in November-December 2020 because she had come into close contact with a member of the MDC staff who had tested positive for COVID. In addition, the laptop is kept in a locker in the same room where the prison computer is located, so it
DOJ-OGR-00002270

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