mirror-epstein-docs/results/IMAGES001/DOJ-OGR-00001351.json

{
  "document_metadata": {
    "page_number": "2",
    "document_number": "20 Cr. 330 (AJN)",
    "date": "January 14, 2021",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": true
  },
  "full_text": "Case1:20-cr-00330-AJN Document121-2 Filed01/15/21 Page2 of 2\nCOHEN & GRESSER LLP\n800 Third Avenue\nNew York, NY 10022\n+1 212 957 7400 phone\nChristian R. Everdell\n+1 (212) 957-7600\nceverdell@cohengresser.com\nUSDC SDNY\nDOCUMENT\nELECTRONICALLY FILED\nDOC#:\nDATE FILED: 1/15/21\nJanuary 14, 2021\nBY ECF\nThe Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\nUnited States Courthouse\n40 Foley Square\nNew York, NY 10007\nRe: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)\nDear Judge Nathan:\nWe 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.\nAt 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.\nDefense 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.\nThere 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\nDOJ-OGR-00001351",
  "text_blocks": [
    {
      "type": "printed",
      "content": "COHEN & GRESSER LLP\n800 Third Avenue\nNew York, NY 10022\n+1 212 957 7400 phone",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Christian R. Everdell\n+1 (212) 957-7600\nceverdell@cohengresser.com",
      "position": "header"
    },
    {
      "type": "stamp",
      "content": "USDC SDNY\nDOCUMENT\nELECTRONICALLY FILED\nDOC#:\nDATE FILED: 1/15/21",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "January 14, 2021",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "BY ECF\nThe Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\nUnited States Courthouse\n40 Foley Square\nNew York, NY 10007",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)\nDear Judge Nathan:",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "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.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "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.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "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.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "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",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00001351",
      "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",
      "Bureau of Prisons",
      "MDC"
    ],
    "locations": [
      "New York",
      "NY",
      "United States"
    ],
    "dates": [
      "January 14, 2021",
      "July 12, 2021",
      "November-December 2020",
      "1/15/21"
    ],
    "reference_numbers": [
      "20 Cr. 330 (AJN)",
      "DOJ-OGR-00001351"
    ]
  },
  "additional_notes": "The document appears to be a letter from COHEN & GRESSER LLP to the Honorable Alison J. Nathan, requesting that the Court order the Bureau of Prisons to give Ghislaine Maxwell access to a laptop computer provided by the government. The letter is dated January 14, 2021, and is related to the case United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)."
}