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Case 1:20-cr-00330-AJN Document 115 Filed 01/14/21 Page 2 of 2 The Honorable Alison J. Nathan January 14, 2021 Page 2 would not require any change in Ms. Maxwell’s movements to give her the requested access. Furthermore, on at least three occasions since she was released from quarantine, Ms. Maxwell’s security team gave her the laptop to review discovery on the weekend. There is clearly no actual impediment preventing the MDC staff from providing Ms. Maxwell access to the laptop on weekends and holidays. Given the millions of documents that Ms. Maxwell must review before trial in order to prepare her defense, it is critical that she be given as much time as possible with the laptop to review the discovery. We therefore respectfully request that the Court order the BOP to give Ms. Maxwell access to the laptop on weekends and holidays during the hours that she is permitted to review discovery. Sincerely, /s/ Christian Everdell Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue, 21st Floor New York, New York 10022 (212) 957-7600 ce: All Counsel of Record (By ECF) DOJ-OGR-00002269