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Case 1:20-cr-00330-AJN Document 130 Filed 02/01/21 Page 1 of 3 LAW OFFICES OF BOBBI C. STERNHEIA 212-243-1100 © Main 33 West 19th Street - 4th Floor 917-306-6666 ® Cell New York, New York 10011 888-587-4737 ° Fax bc@sternheimlaw.com February 1, 2021 Honorable Alison J. Nathan United States District Judge United States Courthouse 40 Foley Square New York, NY 10007 Re. United States v. Ghislaine Maxwell 20 Cr. 330 (AJN) Dear Judge Nathan: By letter to the Court, dated January 25, 2021 (Dkt.117 at 2-3), the MDC raised objection to the Court’s order, unopposed by the government, directing the MDC to permit Ms. Maxwell to use on a laptop computer on weekends and holidays. (Dkt. 116 at 2). The MDC has failed to state a valid or compelling reason for opposing the Court’s directive. The MDC does not identify any valid reason why Ms. Maxwell cannot have access to the laptop computer on weekends and holidays. The MDC does not argue, for example, that access to the laptop cannot be provided because of issues related to safety or security, staffing, or (to quote the government) the need to “manag[e] its inmate population.” Instead, in opposition to the Court’s order, the MDC repeats its stock response: Ms. Maxwell has received significant amount of time to review her discovery and has more contact with counsel than any other MDC inmate is allotted. The MDC’s fixation on the relative time Ms. Maxwell has been given to review discovery is totally misguided. The government has produced millions of pages of discovery. Ms. Maxwell has the right to review all of them in order to prepare her defense for trial. To do that, she needs access to the laptop for as much time as possible, including the weekends and holidays because the prison computers are incapable of reading the millions of discovery documents. Ms. Maxwell loses 10 or more hours per week due to delay in receiving the laptop, problems caused by the MDC computer, and inability to access the computer during morning and afternoon counts on the weekends. Comparing Ms. Maxwell to other inmates does not justify restricting her use of the laptop to review discovery. The MDC’s proposed solution—that Ms. Maxwell can simply use the prison computer on the weekends and holidays to review discovery—is utterly inadequate. As Ms. Maxwell has pointed out on many occasions, the prison computer is incapable of reading a significant portion of the discovery, including but not limited to native files, Excel files, some video and audio files, and anything requiring Cellebrite software. The MDC concedes this fact in their letter—Ms. Maxwell cannot review all of her discovery on the prison computer. And using it causes a colossal waste of time. For example, if Ms. Maxwell locates a document on the prison computer DOJ-OGR- 00002339