EFTA00073190.pdf

GG COHEN & GRESSER LLP Christian R. Evercle11 +1 (212) 957-7600 ccvcrdclIgathcngresscr.com August 27, 2020 BY EMAIL. , Esq. Esq. Esq. United States Attorney's Office Southern District of New York 1 St. Andrew's Plaza New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) De 000 Thud Avenue New Yoek. NY 10022 +1 212 957 7600 phone owswoohensresser corn We write to alert you to several problems with the discovery productions that have been provided to Ms. Maxwell in the MDC, and to register our dissatisfaction with the manner in which that discovery was provided. First, according to Judge Nathan's scheduling order (Dkt. 25), the deadline for completing production of initial non-electronic discovery was Friday, August 21, 2020. Ms. Maxwell did not receive her copy of the third and final production in this phase of discovery until the late morning on Tuesday, August 25, several days after the deadline imposed by the court. It is critical that Ms. Maxwell receive her copy of the discovery productions in a timely manner and on the schedule set by the court. We trust that the government will abide by these deadlines as it produces the remainder of the discovery by November 9, 2020. Second, Ms. Maxwell has experienced numerous difficulties reviewing the documents provided to her in discovery. For example, she cannot open any of the documents listed in the chart below. Ms. Maxwell also cannot open any audio or video files.' Accordingly, we request that the government (1) immediately reproduce to Ms. Maxwell, on a new hard drive, the entire set of initial non-electronic discovery (Bates numbers SDNY GM 00000001 - SDNY GM 00174966) in a format that she can access on her computer I On our call earlier today, you indicated that you received word from t the MDC that the problem with the audio and video files may have been resolved. We have not been a e to confirm this with Ms. Maxwell, but we will do so the next time we speak with her. If the problem has not been resolved, we will notify you. EFTA00073190 August 27, 2020 Page 2 at the MDC, and (2) provide the appropriate software tools that will allow her to review all of the discovery files. Discovery Drive No Bates Numbers Discovery Drive I 963-1284 3699-3700 3703-4639 4791 5417 5431-5432 5435 5487-5488 5490-5491 6007-6010 6097-6129 6130-7086 7426-7461 7521-7581 7654-7650 7666 7676-7677 9087-9088 11489-11491 12200 12217 12305 12359 12376 12382 12396 Discovery Drive 2 20171 20182 20225 20269 20277 20333 20335 20337 23699 29787 EFTA00073191 August 27, 2020 Page 3 36700 68242 68243-68244 Discovery Drive 3 76863-78659 78660-81546 86557-96055 96056-110316 153906 155211-156068 156069-157024 157025-157521 157522-157588 157589-157617 157618-159387 161772-164232 164817-164919 164920-165517 Thank you in advance for your assistance in this matter. Sincerely, Is/ Christian Everdell Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue, 21st Floor k 10022 cc: Mark S. Cohen, Esq. Jeff Pagliuca, Esq. Laura Menninger, Esq. EFTA00073192