EFTA00022514.pdf
117 KB
Extraction Summary
3
People
5
Organizations
3
Locations
3
Events
2
Relationships
3
Quotes
Document Information
Type:
Legal correspondence / court order
File Size:
117 KB
Summary
This document is a letter motion filed by Ghislaine Maxwell's defense attorney, Christian Everdell, on April 30, 2021, requesting Judge Alison Nathan to order the Metropolitan Detention Center (MDC) to accept two hard drives containing discovery materials for Maxwell's review. The defense argues the current format of 2.2 million pages is difficult to navigate, and they have reorganized the files to be more user-friendly. Judge Nathan granted the order on May 3, 2021, with a stipulation allowing MDC counsel to submit objections by May 4, 2021.
People (3)
| Name | Role | Context |
|---|---|---|
| Christian R. Everdell | Defense Counsel |
Author of the letter representing Ghislaine Maxwell.
|
| Alison J. Nathan | Judge |
United States District Court Judge presiding over the case; issued the 'So Ordered' directive.
|
| Ghislaine Maxwell | Defendant |
Subject of the case; currently detained at MDC; requesting hard drives for discovery review.
|
Organizations (5)
| Name | Type | Context |
|---|---|---|
| Cohen & Gresser LLP |
Law firm representing Ghislaine Maxwell.
|
|
| United States District Court Southern District of New York |
Court handling the case.
|
|
| MDC |
Metropolitan Detention Center; facility housing Maxwell.
|
|
| MDC Legal Department |
Legal department of the detention facility.
|
|
| U.S. Attorney's Office |
Prosecution (The Government).
|
Timeline (3 events)
2020-11-18
Discovery production by the government containing roughly 2.2 million pages.
N/A
Government
Defense Counsel
2021-05-03
Judge Nathan 'So Ordered' the request with a condition allowing MDC to object by May 4.
SDNY Court
Locations (3)
| Location | Context |
|---|---|
|
Address of Cohen & Gresser LLP.
|
|
|
Location of the court.
|
|
|
Facility where Maxwell is detained.
|
Relationships (2)
Everdell writes on behalf of Maxwell as defense counsel.
Nathan is the judge presiding over Maxwell's criminal case.
Key Quotes (3)
"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."Source
EFTA00022514.pdf
Quote #1
"For example, the November 18, 2020 production containing roughly 2.2 million pages was produced in load file format"Source
EFTA00022514.pdf
Quote #2
"Counsel for the MDC may submit any objection to the Defendant's request by May 4, 2021. SO ORDERED."Source
EFTA00022514.pdf
Quote #3
Full Extracted Text
Complete text extracted from the document (3,073 characters)
Case 1:20-cr-00330-AJN Document 260 Filed 04/30/21 Page 1 of 2
COHEN & GRESSER LLP
800 Third Avenue
New York, NY 10022
+1 212 957 7600 phone
www.cohengresser.com
COHEN & GRESSER LLP
800 Third Avenue
New York, NY 10022
+1 212 957 7600 phone
www.cohengresser.com
Christian R. Everdell
[REDACTED]
[REDACTED]
[REDACTED]
[REDACTED]
USDC SDNY
DOCUMENT
ELECTRONICALLY FILED
DOC #:
DATE FILED: 5/3/21
DOCUMENT
ELECTRONICALLY FILED
DOC #:
DATE FILED: 5/3/21
April 30, 2021
BY ECF
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
United States Courthouse
[REDACTED]
[REDACTED]
United States District Court
Southern District of New York
United States Courthouse
[REDACTED]
[REDACTED]
5/3/21
/s/ Alison J. Nathan
SO ORDERED.
ALISON J. NATHAN, U.S.D.J.
/s/ Alison J. Nathan
SO ORDERED.
ALISON J. NATHAN, U.S.D.J.
Counsel for the MDC may
submit any objection to
the Defendant's request by
May 4, 2021.
SO ORDERED.
submit any objection to
the Defendant's request by
May 4, 2021.
SO ORDERED.
Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
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.
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.
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.
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
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
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.
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
[REDACTED]
COHEN & GRESSER LLP
[REDACTED]
[REDACTED]
[REDACTED]
COHEN & GRESSER LLP
[REDACTED]
[REDACTED]
cc: All Counsel of Record (By ECF)
MDC Legal Department
MDC Legal Department
EFTA00022515
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