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Case 21-58, Document 76, 04/19/2021, 3080288, Page8 of 30 inmate, few of which are preparing for trial. Over 97% of criminal defendants plead guilty and, therefore, need far less time with their lawyers. Of the remaining 3% who do proceed to trial, the vast majority are out on bond. For those few in custody, how many involve anonymous accusations that are decades old and 2.7 million pages?” And how often is such a defendant forced to prepare her case during a pandemic where in-person lawyer visits are unsafe and impractical? It is no wonder that courts around the country are ordering temporary release under § 3142() for the few defendants who are trying to prepare for trial during the pandemic. The Government’s weak response is that Ms. Maxwell only mentioned temporary release at the first bail hearing. The Government suggests waiver, without saying it. Nonsense. Ms. Maxwell has repeatedly pressed her inability to effectively prepare her defense, which is properly “To illustrate, for Ms. Maxwell to review the 2.7 million pages, she would have to do it, page by page, on a computer screen. If she spent only 1 minute per page, it would take 45,000 hours or 3,750 days (at 12 hours a day), without taking any notes, without discussing a single page with her lawyers, and not including the discovery that is on the way. Although the Government labels this new discovery “non-testifying witness discovery,” it really is Brady material which severely undermines the already weak case. DOJ-OGR- 00020298