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Case 1:20-cr-00330-PAE Document 246 Filed 04/23/21 Page10of13 The Hon. Alison J. Nathan April 22, 2021 Page 10 voluminous photographs from this time period that are in the discovery. The metadata associated with thousands of these photographs that were produced to counsel (but missing from Ms. Maxwell’s production) were stripped and included in Excel spreadsheets. One of the Excel spreadsheets is not functioning, and the government has been asked to provide a replacement. The two functioning Excel spreadsheets contain the file names, not the Bates-stamps, of the associated photographs, so there is no way to match the photographs with its metadata. The Excel spreadsheets contains both photographs that were produced to counsel and also photographs that were not produced, without identifying which is which. Moreover, the government did not indicate on the file names or the spreadsheets which photographs it considered “Highly Confidential” under the case’s protective order. Beginning on April 13, 2021, Ms. Maxwell and one or more of her lawyers undertook an evidence review in the courthouse in conjunction with the prosecution and FBI. Under the terms of the protective order, defense counsel are not allowed to possess “highly confidential material.” The 4 days set aside to review this material was insufficient. The government placed approximately 5,000 images it contends are Highly Confidential on two hard drives. When defense counsel first attempted to view the images, the one laptop designated for the task by the government was insufficient either because of the laptop or the software on the laptop. On Thursday, April 15, a functioning computer was provided to defense counsel. A review of the images revealed no good reason why the hard drives, which do not appear to contain prohibited visual depictions restricted by18 U.S. § 2256, cannot be copied and provided to defense counsel. The sheer number of images make it impossible for any effective review to take place in a government office with various proctors. Should defense counsel need to analyze the metadata, 10 DOJ-OGR-00003997