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Case 1:20-cr-00330-PAE Document 705 Filed 07/12/22 Page /7of12 The Honorable Alison J. Nathan May 12, 2021 Page 7 of the same entry, produced in the criminal discovery and attached as exhibit B, is obviously, and noticeably, different. The remaining six pages are identical except for the identifying bate ranges. Examination of the original document would answer legitimate questions about whether the document has been manipulated, altered, or fabricated. Disclosure of the document in advance of trial would prevent the unnecessary delay of having a qualified forensic document examiner take possession of the document, run tests, and offer an opinion during the middle of trial. Request 10, the Boots The Court directed the government “‘to notify the Court of its views” regarding item 10. Instead of notifying the Court of its “views” the government, however, has taken steps to circumvent the pending defense subpoena request; it is “working to moot request 10” by having the FBI secure the boots, Dkt. 269, p.2. This is an interference with Ms. Maxwell's ability to investigate her defense without interference from the government. Ms. Maxwell's original request was ex parte, now the government is taking possession of the very things subject to Ms. Maxwell's subpoena. The government’s actions demonstrate a willingness to take control of evidence when it is tactically advantageous to do so but resist disclosure when it is not. Ms. Maxwell requests that the court order production of the boots to her lawyers pursuant to the subpoena, not to the government. Request 11, the Photographs Regarding item 11, the photographs, the government offers inconsistent and illogical positions. In its letter of May 4, 2021, the government first advised the Court that it obtained “copies of the complete set of requested photographs” which it then produced to the defense. Two days later it admitted that “some of the original photographs are currently in the Prosecution Team’s possession” and that it would “make them available to the defendant upon request.” DOJ-OGR-00011247