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Case 1:20-cr-00330-PAE Document 705 Filed 07/12/22 Page8of12 The Honorable Alison J. Nathan May 12, 2021 Page 8 (Dkt. 271, p.1) Tripping over its own largess, the “Prosecution Team” neglected to mention that Ms. Maxwell and her lawyers traveled to New York to review all of the physical evidence, including original photographs, in person, at considerable expense from April 12 to April 16, 2021. The government does not explain which original photographs it has in its possession nor does it offer any reason why these photographs were not made available “upon request.” Attempts to confer with the government to explain these discrepancies have gone unanswered for days. Photocopies, in most cases, (and most certainly in this case) are not adequate substitutes for originals, particularly when the photocopies are produced by lawyers adverse to Ms. Maxwell, were not collected by law enforcement directly from the source, and are subject to manipulation. Any original photographs will have markings that identify when the film was developed and other indicia indicating whether they are genuine or not. Again, like the journal, the government has outsourced the fact and truth finding function regarding the photographs to partisan advocates. If the government possessed the originals Ms. Maxwell would have the Rule 16 right to inspect them, just like the many photographs she inspected between April 12 and April 16, 2021. Finally, the government devotes much of its submission attempting to bait Ms. Maxwell into revealing defense strategy and work product. Ms. Maxwell is happy to address any questions regarding relevance and admissibility ex-parte should the Court need any additional information. Respectfully Submitted, Jeffrey S. Pagliuca CC: Counsel of Record (via ECF) DOJ-OGR-00011248