{
  "document_metadata": {
    "page_number": "1 of 2",
    "document_number": "20 Cr. 330 (AJN)",
    "date": "April 30, 2021",
    "document_type": "Letter to Judge",
    "has_handwriting": true,
    "has_stamps": false
  },
  "full_text": "COHEN & GRESSER LLP\nChristian R. Everdell\n+1 (212) 957-7600\neverdell@cohengresser.com\n800 Third Avenue\nNew York, NY 10022\n+1 212 957 7600 phone\nwww.cohengresser.com\n\nUSDC SDNY\nDOCUMENT\nELECTRONICALLY FILED\nDOC #:\nDATE FILED: 5/3/21\n\nApril 30, 2021\n\nBY ECF\n\nThe Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\nUnited States Courthouse\n40 Foley Square\nNew York, NY 10007\n\nRe: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)\n\nDear Judge Nathan:\n\nWe 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.\n\nIn 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.\n\nDefense 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 loaded and certified by the U.S. Attorney's Office. We have conferred with the government, which has advised that it does not object to the defense making an application to the Court to issue an order directing the MDC to accept the hard drives. The government requested, however, that the Court allow MDC legal counsel the opportunity to note their objections to the Court.\n\nCounsel for the MDC may submit any objection to the Defendant's request by May 4, 2021.\nSO ORDERED.\n\nSO ORDERED.\nALISON J. NATHAN, U.S.D.J.\n5/3/21\n\nDOJ-OGR-00004075",
  "text_blocks": [
    {
      "type": "printed",
      "content": "COHEN & GRESSER LLP\nChristian R. Everdell\n+1 (212) 957-7600\neverdell@cohengresser.com",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "800 Third Avenue\nNew York, NY 10022\n+1 212 957 7600 phone\nwww.cohengresser.com",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "USDC SDNY\nDOCUMENT\nELECTRONICALLY FILED\nDOC #:\nDATE FILED: 5/3/21",
      "position": "margin"
    },
    {
      "type": "printed",
      "content": "April 30, 2021",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "BY ECF",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\nUnited States Courthouse\n40 Foley Square\nNew York, NY 10007",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Dear Judge Nathan:",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "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.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "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.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "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 loaded and certified by the U.S. Attorney's Office. We have conferred with the government, which has advised that it does not object to the defense making an application to the Court to issue an order directing the MDC to accept the hard drives. The government requested, however, that the Court allow MDC legal counsel the opportunity to note their objections to the Court.",
      "position": "body"
    },
    {
      "type": "handwritten",
      "content": "SO ORDERED.\nALISON J. NATHAN, U.S.D.J.\n5/3/21",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "Counsel for the MDC may submit any objection to the Defendant's request by May 4, 2021.\nSO ORDERED.",
      "position": "margin"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00004075",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Christian R. Everdell",
      "Alison J. Nathan",
      "Ghislaine Maxwell"
    ],
    "organizations": [
      "COHEN & GRESSER LLP",
      "United States District Court",
      "Southern District of New York",
      "U.S. Attorney's Office",
      "MDC Legal Department"
    ],
    "locations": [
      "New York",
      "NY",
      "United States"
    ],
    "dates": [
      "April 30, 2021",
      "May 4, 2021",
      "November 18, 2020",
      "5/3/21"
    ],
    "reference_numbers": [
      "20 Cr. 330 (AJN)",
      "DOJ-OGR-00004075"
    ]
  },
  "additional_notes": "The document is a letter to Judge Alison J. Nathan from Christian R. Everdell of COHEN & GRESSER LLP, requesting the Court to issue an order to the MDC to accept two hard drives containing non-Highly Confidential discovery for Ghislaine Maxwell's use. The letter is dated April 30, 2021, and is signed by the judge on 5/3/21."
}