Document 117

Case 1:20-cr-00330-AJN Document 117 Filed 01/25/21 Page 1 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK United States of America, -v- Ghislain Maxwell, Defendant. 20-CR-330 (AJN) ORDER ALISON J. NATHAN, District Judge: On January 25, 2021, the Court received by email the attached letter from the Bureau of Prisons ("BOP"). In the letter, the BOP requests that the Court vacate its January 15, 2021 Order, Dkt. No. 116, which directed the BOP to give the Defendant access to her Government-provided laptop computer on weekends and holidays during the hours that she is permitted to review discovery. The Defendant and the Government may respond to the BOP's letter within one week of this Order. SO ORDERED. Dated: January 25, 2021 New York, New York ALISON J. NATHAN United States District Judge 1 DOJ-OGR-00002272 --- PAGE BREAK --- Case 1:20-cr-00330-AJN Document 117 Filed 01/25/21 Page 2 of 3 U.S. DEPARTMENT OF JUSTICE Federal Bureau of Prisons Metropolitan Detention Center 80 29th Street Brooklyn, New York 11232 January 25, 2021 BY ECF The Honorable Alison J. Nathan United States District Court Southern District of New York 40 Foley Square New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Ghislaine Maxwell, Reg. No. 02879-509 Dear Judge Nathan: This letter is written in response to Order granted on January 15, 2021, concerning Ghislaine Maxwell, Reg. 02879-509., an inmate currently confined at the Metropolitan Detention Center ("MDC") in Brooklyn, New York. The MDC Brooklyn respectfully requests that Your Honor vacate the Order given MDC Brooklyn was not given the opportunity to object to defense counsel's claims, although the objection had been reiterated to the U.S. Attorney's Office numerous times. Defense counsel expressed various concerns regarding Ms. Maxwell's confinement limiting her access to discovery. However, Ms. Maxwell has received a significant amount of time to review her discovery. On November 18, 2020, the Government provided the MDC Brooklyn with a laptop for Ms. Maxwell to use to review discovery. Ms. Maxwell has been and will continue to be permitted to use that laptop to review her discovery for thirteen (13) hours per day, five (5) days per week. In addition to the Government laptop, she has access to the MDC Brooklyn discovery computers. Although defense counsel has indicated that the MDC Brooklyn discovery computers are not equipped to read all of her electronic discovery, the computers are capable of reviewing most of the electronic discovery. Despite defense counsel's claim that Ms. Maxwell's lacks sufficient time to fully review her discovery, her consistent use of Government laptop and MDC Brooklyn's discovery computers undercuts this claim. Moreover, Ms. Maxwell continues to have contact with her legal counsel five (5) days per week, three (3) hours per day via video-teleconference and via telephone; this is far more time than any other MDC inmate is allotted to communicate with their attorneys. DOJ-OGR-00002273 --- PAGE BREAK --- Case 1:20-cr-00330-AJN Document 117 Filed 01/25/21 Page 3 of 3 We respectfully request that Your Honor vacate the order of January 15, 2021, and allow the institution to resume the prior schedule of laptop access, Monday through Friday, 7:00 AM - 8:00 PM. Respectfully submitted, /s/ Sophia Papapetru Sophia Papapetru Staff Attorney MDC Brooklyn Federal Bureau of Prisons DOJ-OGR-00002274 --- PAGE BREAK --- Case 20-cr-00330-AJN Document 117 Filed 08/20/20 Page 30 of 125 Q. List all the people under the age of 18 that you interacted with at any of Jeffrey's properties? A. I'm not aware of anybody that I interacted with, other than obviously [the plaintiff] who was 17 at this point. (Title 18, United States Code, Section 1623.) COUNT SIX (Perjury) The Grand Jury further charges: 22. The allegations contained in paragraphs 1 through 8 of this Indictment are repeated and realleged as if fully set forth within. 23. On or about July 22, 2016, in the Southern District of New York, GHISLAINE MAXWELL, the defendant, having taken an oath to testify truthfully in a deposition in connection with a case then pending before the United States District Court for the Southern District of New York under docket number 15 Civ. 7433, knowingly made false material declarations, to wit, MAXWELL gave the following underlined false testimony: Q: Were you aware of the presence of sex toys or devices used in sexual activities in Mr. Epstein's Palm Beach house? A: No, not that I recall. . . . Q. Do you know whether Mr. Epstein possessed sex toys or devices used in sexual activities? A. No. 16 App.028 DOJ-OGR-00019487