What is document EFTA00020244?

This is a legal letter from Ghislaine Maxwell's defense attorney Christian R. Everdell (Cohen & Gresser LLP) to Judge Alison J. Nathan, filed April 30, 2021, requesting a court order directing MDC (Metropolitan Detention Center) to accept hard drives containing case discovery materials for Maxwell's use during pretrial detention.

Who is mentioned in this document?

The key figures are Ghislaine Maxwell (defendant), Judge Alison J. Nathan (presiding judge), Christian R. Everdell (defense attorney from Cohen & Gresser LLP), the MDC Legal Department, and the U.S. Attorney's Office for the Southern District of New York.

What does this document reveal about Maxwell's detention conditions?

The document reveals procedural challenges Maxwell faced in preparing her defense while detained. She needed court intervention to access organized discovery materials because MDC policies restricted what her attorneys could provide directly. The defense team had to reorganize approximately 2.2 million pages of discovery documents into a more usable format, and even then required judicial approval to deliver them.

How much discovery material was involved in Maxwell's case?

By November 2020, the government had produced roughly 2.2 million pages of discovery in various digital formats. The defense team consolidated these materials onto two hard drives, excluding materials marked 'Highly Confidential' that Maxwell was prohibited from possessing under the Protective Order.

Did prosecutors object to Maxwell receiving these materials?

No. The document states that defense counsel conferred with the government, which advised it did not object to the defense making this application to the Court. The issue was institutional policy at MDC, not prosecutorial opposition.

What is document EFTA00020244?

This is a legal letter from Ghislaine Maxwell's defense attorney Christian R. Everdell (Cohen & Gresser LLP) to Judge Alison J. Nathan, filed April 30, 2021, requesting a court order directing MDC (Metropolitan Detention Center) to accept hard drives containing case discovery materials for Maxwell's use during pretrial detention.

Who is mentioned in this document?

The key figures are Ghislaine Maxwell (defendant), Judge Alison J. Nathan (presiding judge), Christian R. Everdell (defense attorney from Cohen & Gresser LLP), the MDC Legal Department, and the U.S. Attorney's Office for the Southern District of New York.

What does this document reveal about Maxwell's detention conditions?

The document reveals procedural challenges Maxwell faced in preparing her defense while detained. She needed court intervention to access organized discovery materials because MDC policies restricted what her attorneys could provide directly. The defense team had to reorganize approximately 2.2 million pages of discovery documents into a more usable format, and even then required judicial approval to deliver them.

How much discovery material was involved in Maxwell's case?

By November 2020, the government had produced roughly 2.2 million pages of discovery in various digital formats. The defense team consolidated these materials onto two hard drives, excluding materials marked 'Highly Confidential' that Maxwell was prohibited from possessing under the Protective Order.

Did prosecutors object to Maxwell receiving these materials?

No. The document states that defense counsel conferred with the government, which advised it did not object to the defense making this application to the Court. The issue was institutional policy at MDC, not prosecutorial opposition.

EFTA00020244 - EFTA00020245

This is a legal letter from defense attorney Christian R. Everdell to Judge Alison J. Nathan requesting court intervention to allow Ghislaine Maxwell access to discovery materials while detained at MDC.

Filed on April 30, 2021, during Maxwell's pretrial detention, this letter addresses a procedural issue with providing discovery materials to the defendant. Defense counsel created organized hard drives containing approximately 2.2 million pages of non-classified discovery documents but faced institutional barriers: MDC policy only allowed hard drives certified by the U.S. Attorney's Office. The defense team reorganized the November 18, 2020 production into a more user-friendly format, consolidating scattered files and eliminating duplicates to facilitate Maxwell's case preparation.

Key Highlights

•Maxwell's defense team prepared 2.2 million pages of discovery in an organized format to help her prepare for trial
•MDC institutional policies created obstacles to Maxwell reviewing case materials, requiring court intervention
•The discovery excluded 'Highly Confidential' materials Maxwell was barred from possessing under the Protective Order
•Defense successfully coordinated with prosecutors who did not object to the request

Frequently Asked Questions

Books for Further Reading

The Spider: Inside the Tangled Web of Jeffrey Epstein and Ghislaine Maxwell

Perversion of Justice: The Jeffrey Epstein Story

Julie K. Brown

Investigative journalism that broke the Epstein case open

Filthy Rich: The Jeffrey Epstein Story

James Patterson

Bestselling account of Epstein's crimes and network

Document Information

Bates Range

EFTA00020244 - EFTA00020245

Pages

Document Content

Page 1 - EFTA00020244

Case 1:20-cr-00330-AJN Document 260 Filed 04/30/21 Page 1 of 2 COHEN & GRESSER LLP Chnstian R. ItatrdcII April 30, 2021 BY ECF The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Judge Nathan: We write to respectfully request the Court to issue an order to the MDC directing it to accept two hard drives from defense counsel that contain the non-Highly Confidential discovery in this case for Ms. Maxwell's use at the MDC. In an effort to facilitate Ms. Maxwell's review of the discovery, defense counsel have created a master set of two hard drives that contain a complete set of the discovery produced by the government so far, excluding the materials marked Highly Confidential, which Ms. Maxwell is not permitted to possess in the MDC pursuant to the terms of the Protective Order. The master drives are easier to use than her existing hard drives because they collect all of the material in one place and organize the documents in a more user-friendly format. For example, the November 18, 2020 production containing roughly 2.2 million pages was produced in load file format, which contains images of individual pages of documents in native file format, image file format, and other formats. The hard drives organize these files by document, as opposed to by page, and eliminate duplicative file formats so that Ms. Maxwell will not have to add countless hours to her review. Defense counsel would like to send these hard drives to Ms. Maxwell for her to use in the MDC. We were informed by the MDC Legal Department that they are only permitted to accept hard drives that are loaded and certified by the U.S. Attorney's Office. We have conferred with the government, which has advised that it does not object to the defense making an application to the Court to issue an order directing the MDC to accept the hard drives. The government requested, however, that the Court allow MDC legal counsel the opportunity to note their objections to the Court. EFTA00020244

Page 2 - EFTA00020245

Case 1:20-cr-00330-AJN Document 260 Filed 04/30/21 Page 2 of 2 The Honorable Alison J. Nathan April 30, 2021 Page 2 Accordingly, we respectfully request that the Court issue an order directing the MDC to accept the master hard drives either from defense counsel or from the government. We will send a copy of this letter to the MDC Legal Department so that they can note any objections they may have. Thank you for your attention to this matter. Sincerely, /s/ Christian Everdell Christian R. Everdell COHEN & GRESSER LLP New York, New York 10022 cc: All Counsel of Record (By ECF) MDC Legal Department EFTA00020245