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Case#: 2020cr00308P3AEJN Document#: 41252 Filed:11/8/2021 Page#: 1 of 2 U.S Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 November 8, 2021 BY ECF The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully submits this letter in response to the Court's Order dated November 3, 2021, ordering the Government to docket a letter with a proposal from legal counsel at the Metropolitan Detention Center ("MDC") regarding what additional steps can be taken to ensure that the defendant promptly receives her legal mail within the weeks leading up to trial (Dkt. No. 412). Legal counsel at the MDC informed the Government of the following: MDC mail room staff will continue to pick up legal mail from the post office once every business day and follow the processes outlined in the Government's November 1, 2021 letter (Dkt. No. 403). As to electronic discovery sent to legal counsel at the MDC, staff at the MDC's warehouse will continue to process and log the mail and the legal department will deliver the mail to the inmate. Legal counsel at the MDC has indicated that they call or stop by the warehouse every day or every other day to check for packages that have been delivered for the Legal Department.1 The Government will continue to inform legal counsel at the MDC when it sends a hard drive to the attention of legal counsel, which goes to the MDC's warehouse as outlined in the Government's October 15, 2021 letter (Dkt. No. 350). DOJ-OGR-00006308