This document is an internal email chain within the US Attorney's Office for the Southern District of New York (USANYS) from December 2020. It discusses a legal issue raised by Judge Engelmayer in the case of *United States v. Rivera*, where the judge criticized the Bureau of Prisons (BOP) for providing significantly better access to counsel and electronic discovery to Ghislaine Maxwell (at MDC) compared to Justin Rivera (at MCC). The emails detail the drafting of a declaration to explain that Maxwell's privileges (such as 13 hours/day of laptop access) are due to her unique protective custody status and the massive volume of discovery in her case, whereas Rivera is in the general population with shared resources.
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