Who is mentioned in this document?

The document mentions Judge Alison J. Nathan (presiding judge), Christian Everdell (Maxwell's attorney from Cohen & Gresser LLP), Ghislaine Maxwell (the defendant), and references the MDC Legal Department and U.S. Attorney's Office.

What does this document reveal?

The document reveals that Maxwell's defense team had to reorganize approximately 2.2 million pages of discovery evidence and required a court order just to deliver hard drives to her at the detention center. It shows the practical barriers to preparing a defense while incarcerated and that Maxwell was restricted from accessing certain 'Highly Confidential' materials pursuant to a protective order.

Why did Maxwell's lawyers need court permission for hard drives?

The MDC (Metropolitan Detention Center) Legal Department would only accept hard drives containing discovery materials if authorized by a court order. This procedural requirement meant Maxwell's attorneys had to formally request Judge Nathan's approval before providing her with the reorganized evidence files.

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

According to this document, the government's November 18, 2020 production alone contained roughly 2.2 million pages in various file formats. The defense team consolidated all non-classified discovery materials onto two hard drives, organizing them by document rather than individual pages for easier review.

Who is mentioned in this document?

The document mentions Judge Alison J. Nathan (presiding judge), Christian Everdell (Maxwell's attorney from Cohen & Gresser LLP), Ghislaine Maxwell (the defendant), and references the MDC Legal Department and U.S. Attorney's Office.

What does this document reveal?

The document reveals that Maxwell's defense team had to reorganize approximately 2.2 million pages of discovery evidence and required a court order just to deliver hard drives to her at the detention center. It shows the practical barriers to preparing a defense while incarcerated and that Maxwell was restricted from accessing certain 'Highly Confidential' materials pursuant to a protective order.

Why did Maxwell's lawyers need court permission for hard drives?

The MDC (Metropolitan Detention Center) Legal Department would only accept hard drives containing discovery materials if authorized by a court order. This procedural requirement meant Maxwell's attorneys had to formally request Judge Nathan's approval before providing her with the reorganized evidence files.

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

According to this document, the government's November 18, 2020 production alone contained roughly 2.2 million pages in various file formats. The defense team consolidated all non-classified discovery materials onto two hard drives, organizing them by document rather than individual pages for easier review.

EFTA00022514 - EFTA00022515

This is a letter from Ghislaine Maxwell's defense attorney Christian Everdell to Judge Alison J. Nathan requesting court approval to provide Maxwell with organized hard drives containing non-classified discovery materials for her review while detained at MDC (Metropolitan Detention Center).

Filed on April 30, 2021, this court document shows Maxwell's legal team from Cohen & Gresser LLP seeking permission to deliver two hard drives containing reorganized discovery materials to Maxwell at the detention center. The defense explains they've reorganized approximately 2.2 million pages of evidence into a more user-friendly format, excluding materials marked 'Highly Confidential' per the protective order. The letter reveals the practical challenges of Maxwell reviewing massive amounts of discovery while incarcerated, and demonstrates her legal team's efforts to facilitate her case preparation.

Key Highlights

•Defense team reorganized approximately 2.2 million pages of discovery evidence for easier review
•Maxwell was prohibited from accessing materials marked 'Highly Confidential' while detained at MDC
•The request shows the logistical difficulties of preparing a defense while incarcerated, requiring court orders for basic access to case materials
•MDC Legal Department required court authorization before accepting the hard drives

Frequently Asked Questions

Books for Further Reading

Perversion of Justice

Julie K. Brown

Covers Maxwell's involvement

Ghislaine Maxwell: An Unauthorized Biography: The Shocking True Story of Jeffrey Epstein's Madam

Perversion of Justice: The Jeffrey Epstein Story

Julie K. Brown

Investigative journalism that broke the Epstein case open

Document Information

Bates Range

EFTA00022514 - EFTA00022515

Pages

Document Content

Page 1 - EFTA00022514

Case 1:20-cr-00330-AJN Document 260 Filed 04/30/21 Page 1 of 2 COHEN & GRESSER LLP BY ECF The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse USDC SONY DOCUMENT ELECTRONICALLY FILED DOC 0: DATE FILED: 5/3/21 April 30, 2021 9D OltOUID. ALIION I. mama I Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Judge Nathan: SOO Thad Avenue New Yolk. NY 10022 ♦1 212 957 7600 phono www cohongartav corn Counsel for the MDC may submit any objection to the Defendant's request by May 4, 2021. SO ORDERED. 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. EFTA00022514

Page 2 - EFTA00022515

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 COHEN & GRESSER LLP cc: All Counsel of Record (By ECF) MDC Legal Department EFTA00022515