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ponse to the Maxwell/Rivera issue. We intend to explain that the discovery and counsel access accommodations that have been provided to Maxwell and Rivera, respectively, result from the specific circumstances of their cases, the specific requests of their lawyers, and their individual housing circumsta
o discuss this further. In the meantime, we are working with to identify the appropriate declarant and draft an explanation for the Court. Best, Bhaskaran Assistant United States Attorney United States Attorney's Office for the Southern District of New York One Saint Andrew's Plaza New York NY 10007
ponse to the Maxwell/Rivera issue. We intend to explain that the discovery and counsel access accommodations that have been provided to Maxwell and Rivera, respectively, result from the specific circumstances of their cases, the specific requests of their lawyers, and their individual housing circumsta
o discuss this further. In the meantime, we are working with to identify the appropriate declarant and draft an explanation for the Court. Best, Bhaskaran Assistant United States Attorney United States Attorney's Office for the Southern District of New York One Saint Andrew's Plaza New York NY 10007
ponse to the Maxwell/Rivera issue. We intend to explain that the discovery and counsel access accommodations that have been provided to Maxwell and Rivera, respectively, result from the specific circumstances of their cases, the specific requests of their lawyers, and their individual housing circumsta
USANYS) 1 <ME :z.; (USANYS) < Subject: Re: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera Thanks to you all! Bhaskaran (USANYS) cM > EFTA00086756 Assistant United States Attorney Sent from my iPhone On Dec 30, 2020, at 10:09 PM, wrote: Thanks very much, M, a
u, 31 Dec 2020 00:38:23 +0000 r Attachments: 2020.12.31 tt S r on_Rivera_and_Maxwell_discovery_and_counsel_access_(v.2).docx; 2020.12.31 ecl re Rivera and_ Maxwell Jv.3).docx _ This all appears accurate to me and seems fine to file. Any issues from your perspective? From: (USANYS) Sent: Wednesd
o discuss this further. In the meantime, we are working with to identify the appropriate declarant and draft an explanation for the Court. Best, Bhaskaran Assistant United States Attorney United States Attorney's Office for the Southern District of New York One Saint Andrew's Plaza New York NY 10007
ponse to the Maxwell/Rivera issue. We intend to explain that the discovery and counsel access accommodations that have been provided to Maxwell and Rivera, respectively, result from the specific circumstances of their cases, the specific requests of their lawyers, and their individual housing circumsta
o discuss this further. In the meantime, we are working with to identify the appropriate declarant and draft an explanation for the Court. Best, Bhaskaran Assistant United States Attorney United States Attorney's Office for the Southern District of New York One Saint Andrew's Plaza New York NY moor
es in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera (USANYS) We are in the process of finalizing our response to the Maxwell/Rivera issue. We intend to explain that the discovery and counsel access accommodations that have been provided to Maxwell and Rivera, respectively, resul
Page: EFTA00013338 →it a declaration, from an appropriate person at the BOP, explaining in more detail why the accommodations provided to Maxwell cannot be extended to Rivera. Based on the recent bail opposition in the Maxwell case, I believe the differences in counsel/discovery access are as follows: Accommodation Maxw
Page: EFTA00013340 →MCC for personal health concerns. We have two court orders in place to address these issues: (1) a laptop order, which requires the MCC to provide Rivera access to a laptop for three hours per day; and (2) a videoconference order, which requires the MCC to make available four hours of videoconferencin
Page: EFTA00013340 →o discuss this further. In the meantime, we are working with to identify the appropriate declarant and draft an explanation for the Court. Best, Bhaskaran Assistant United States Attorney United States Attorney's Office for the Southern District of New York One Saint Andrew's Plaza New York NY z0007
Page: EFTA00013341 →Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera Date: Thu, 31 Dec 2020 15:33:39 +0000 Attachments: 2020.12.31 Best Decl _ re_ Rivera and_Maxwell_(v.3).docx; _ _ 2020.12.3I_Letter on_Rivera_anci Maxwell_discovety_and_counsel_accest(v.2). I didn't line edit this but I did catch a
Page: EFTA00013329 →o discuss this further. In the meantime, we are working with to identify the appropriate declarant and draft an explanation for the Court. Best, Bhaskaran Assistant United States Attorney United States Attorney's Office for the Southern District of New York One Saint Andrew's Plaza New York NY 10007
Page: EFTA00013332 →Entities connected to both Rivera and Bhaskaran

Ghislaine Maxwell
PERSON
Prince Andrew
PERSON
Southern District of New York
ORGANIZATION
Justin Trudeau
PERSONEngelmayer
PERSONJustin Rivera
PERSONthe Federal Defenders
ORGANIZATIONDiscovery Access
ORGANIZATIONMaxwell/Rivera
ORGANIZATIONMCC/MDC
ORGANIZATION