COHEN & GRESSER LLP September 21, 2020 BY EMAIL , Esq. Esq. Esq. United States Attorney's Office Southern District of New York 1 St. Andrew's Plaza New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) De 800 Thrd Avon,* New York NY 10022 ♦1 212 957 7600 phone wenecohengesseecom We write to address three issues. First, we write to express once again our dissatisfaction with the incomplete and inadequate production of discovery to Ms. Maxwell in the MDC, and to demand that the government find an immediate solution that will permit Ms. Maxwell to review all of the discovery materials produced to date. Second, we write to request that the government set up a time at the earliest convenience when Ms. Maxwell and defense counsel can review the documents marked as "Highly Confidential" in the discovery materials. Third, we write to register our objection to the onerous conditions of confinement to which Ms. Maxwell is subjected, which are entirely unique to Ms. Maxwell. We request that the government intercede directly with the BOP to improve these conditions, as set forth below. 1. Ms. Maxwell Still Cannot Access All of the Discovery One full month has now passed since August 21, 2020, the date the government represented to the Court that it would complete production of the initial group of discovery materials, and Ms. Maxwell still cannot read a substantial portion of the discovery produced to date. The government further represented to the Court at the initial appearance on July 14, 2020 that this initial group of discovery materials represents "the core of the case" against Ms. Maxwell. (Tr. at 12, line 11). Ms. Maxwell has therefore been denied full access to the most critical evidence in this case for a month. This is unacceptable and inconsistent with the government's obligations and its representations to Judge Nathan; this must be fixed immediately. The government represented to the Court at the initial appe