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be N Ww ws Oo OY ~] oO Ke) fan) be N Ww Hs Oo OY ~] oO Ke) Case 21-58, Document 39-2, 04/01/2021, 3068530, Page153 of 200 k7e2MaxC kjc 90 the evidentiary hearing within one week. In contrast, defendant is in the same position as any newly indicted defendant who is incarcerated in terms of the need to access counsel. Indeed the defense's logic, all pretrial detainees currently incarcerated at MDC and any federal facility would their def need to be released to prepar ns To the contrary, the MDC has continued to develop procedures to ensure and the defendants attorney-client access at the facility, detained at MDC are able to conduct video and phone conferences before with their attorneys. There is ongoing litigation District of New York about the Brodie in the Eastern Judge the MDC. That is case adequacy of attorney-client access at 19 Civ. 660. No. Public From filings the court-appointed mediator in that case describe the availability of legal phone calls and video calls, video conferences for the purposes of n detained defendants and their reviewing discovery betw that MDC counsel, and that same report indicates is currently developing a plan to resume in-person attorney-client visits in 20 21 22 23 the near future. At this stage in this case and at this point in the pandemic in New York City, these measures are sufficient to ensure Ms. Maxwell has access to her counsel. To further assuage these concerns, the court orders the government in this to work with the case, and frankly all others before it, defense to provide adequate communication between counsel and SOUTHERN D STRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00020012