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Case 22-1426, Document 3-2, 07/08/2022, 3344434, Page16 of 92 11/18/2020 73. | MEMO ENDORSEMENT as to Ghislaine Maxwell on re: 60 Letter filed by USA as to Ghislaine Maxwell re: The Government respectfully requests that the Court approve the Government's request to delay disclosure of these Materials... ENDORSEMENT...There is no dispute that the materials referenced in the Government's letter will be turned over to the defense. The Government has indicated that it will do so. The only dispute, then, relates to the timing of such disclosure. See Dkt. Nos. 64, 65. Because the Government has articulated plausible reasons for some delay of disclosure, see Dkt. No. 65 at 4, the Court grants the Government's request to delay disclosure. However, the Governments proposal to delay disclosure until 8 weeks in advance of trial is insufficient. In order to ensure that the defense can adequately prepare for trial, the Government shall produce the referenced materials, which are not voluminous, to the defense by March 12, 2021. Disclosure of the materials will of course be subject to the protective order entered by the Court, see Dkt. No. 36. (Government Responses due by 3/12/2021) (Signed by Judge Alison J. Nathan on 11/18/20)(jw) (Entered: 11/18/2020) 11/23/2020 | 74 | LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from AUSAs Maurene Comey, Alison Moe, and Lara Pomerantz dated November 23, 2020 re: Update Regarding Conditions of Confinement Document filed by USA. (Comey, Maurene) (Entered: 11/23/2020) 11/24/2020 | 75 | LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Bobbi C. Sternheim dated 11/24/2020 re: Response to 90-day MDC conditions report (Sternheim, Bobbi) (Entered: 11/24/2020) 11/24/2020 MEMO ENDORSEMENT as to Ghislaine Maxwell on re: 75 LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Bobbi C. Sternheim dated 11/24/2020 re: Response to 90-day MDC conditions report. ENDORSEMENT: The parties are hereby ORDERED to meet and confer regarding Defendant's request that Warden Heriberto Tellez directly address Defendant's concerns regarding the conditions of her detention. The parties shall jointly submit a status update within one week of this Order. (Signed by Judge Alison J. Nathan on 11/24/2020) (ap) (Entered: 11/24/2020) 12/01/2020 ORDER as to Ghislaine Maxwell. On November 25, 2020, the Defendant filed a letter request under seal. On November 30, 2020, she filed a second letter request in which she proposed redactions on both letters. The Government is hereby ORDERED to respond to the Defendant's November 25, 2020 letter request and to the request for proposed redactions by no later than December 2, 2020. The letters shall be temporarily sealed while the Court resolves the redaction request. SO ORDERED. (Signed by Judge Alison J. Nathan on 12/1/2020)(bw) (Entered: 12/01/2020) 12/01/2020 | 78 | LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from AUSAs Maurene Comey, Alison Moe, and Lara Pomerantz dated December 1, 2020 re: Joint Letter regarding Conditions of Confinement Document filed by USA. (Pomerantz, Lara) (Entered: 12/01/2020) 12/02/2020 79 | MEMO ENDORSEMENT as to Ghislaine Maxwell on re: 78 LETTER by USA addressed to Judge Alison J. Nathan from AUSAs Maurene Comey, Alison Moe, and Lara Pomerantz dated December 1, 2020 re: Joint Letter regarding Conditions of Confinement. ENDORSEMENT: MDC legal counsel shall submit their letter to the Court by December 4, 2020. Upon review of that letter, the Court will determine whether any additional information is required, either orally or in writing. SO ORDERED. (Signed by Judge Alison J. Nathan on 12/2/2020)(bw) (Entered: 12/02/2020) 12/02/2020 LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from AUSAs Maurene Comey, Alison Moe, and Lara Pomerantz dated December 2, 2020 re: Defense Requests for Sealing Document filed by USA. (Comey, Maurene) (Entered: 12/02/2020) 12/03/2020 ORDER as to Ghislaine Maxwell. On November 25, 2020, counsel for Defendant Ghislaine Maxwell filed a letter request seeking an in camera conference for the presentation of a renewed motion for release on bail and a request to seal the November 25, 2020 letter in its entirety. The Court required justification for the sealing request. On November 30, 2020, the defense counsel filed a second letter no longer fully pressing the unsupported request to file the letter entirely under seal and DOJ-OGR- 00020502