Document 20-cr-00830-AJN

Case 1:20-cr-00830-AJN Document 110 Filed 06/23/20 Page 216 of 515 TABLE OF CONTENTS Page PRELIMINARY STATEMENT ............................................................................................ 1 ARGUMENT ....................................................................................................................... 2 I. The Government Concedes that Its Case Relies Almost Exclusively on the Testimony of Three Witnesses ............................................................................... 2 II. The Government Has Not Carried Its Burden............................................................ 4 A. The Government Asks the Court to Ignore Ms. Maxwell’s Substantial Ties to the United States, Including Her Spouse ............................................... 4 B. Ms. Maxwell Has Thoroughly Disclosed Her Finances and Pledged All of Her and Her Spouse’s Assets in Support of Her Bond ................................... 5 C. The Government’s Assertion that Ms. Maxwell Is “Adept” at Hiding and Therefore a Flight Risk Is Specious ............................................................... 7 D. Refusal of Extradition from France or the United Kingdom Is Highly Unlikely .................................................................................................................... 8 E. The Recent COVID Surge at MDC Further Justifies Bail .................................... 10 CONCLUSION ................................................................................................................... 10 i DOJ-OGR-00001187 --- PAGE BREAK --- The Honorable Alison J. Nathan January 14, 2021 Page 2 would not require any change in Ms. Maxwell's movements to give her the requested access. Furthermore, on at least three occasions since she was released from quarantine, Ms. Maxwell's security team gave her the laptop to review discovery on the weekend. There is clearly no actual impediment preventing the MDC staff from providing Ms. Maxwell access to the laptop on weekends and holidays. Given the millions of documents that Ms. Maxwell must review before trial in order to prepare her defense, it is critical that she be given as much time as possible with the laptop to review the discovery. We therefore respectfully request that the Court order the BOP to give Ms. Maxwell access to the laptop on weekends and holidays during the hours that she is permitted to review discovery. Sincerely, /s/ Christian Everdell Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue, 21st Floor New York, New York 10022 (212) 957-7600 cc: All Counsel of Record (By ECF) The unobjected-to request is GRANTED. The Bureau of Prisons is ORDERED to give the Defendant access to the laptop computer on weekends and holidays during the hours that she is permitted to review discovery. SO ORDERED. 1/15/21 Alison J. Nathan ALISON J. NATHAN United States District Judge