altask:2C2t3K001818PAQSN Ethmaument2ED FIRite±103138383Eal Patisgk dfc2 2 &GRESSER LLP Christian R. Everdell +1 (212) 957.7600 ccvcrdcllticohcngrcsscr.com USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC N: DATE FILED: 5/3/21 800 Third Aveenr* New York, NY 1O022 +1 212 957 7600 phone wwwicchengrossor corn April 30, 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, NY 10007 Counsel for the MDC may submit any objection to the Defendant's request by May 4, 2021. SO ORDERED. Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: We write to respectfully request the Court to issue an order to the MDC directing it to accept two hard drives from defense counsel that contain the non-Highly Confidential discovery in this case for Ms. Maxwell's use at the MDC. In an effort to facilitate Ms. Maxwell's review of the discovery, defense counsel have created a set of two hard drives that contain a complete set of the discovery produced by the government so far, excluding the materials marked Highly Confidential, which Ms. Maxwell is not permitted to possess in the MDC pursuant to the terms of the Protective Order. The drives are easier to use than her existing hard drives because they collect all of the material in one place and organize the documents in a more user-friendly format. For example, the November 18, 2020 production containing roughly 2.2 million pages was produced in load file format, which contains images of individual pages of documents in native file format, image file format, and other formats. The hard drives organize these files by document, as opposed to by page, and eliminate duplicative file formats so that Ms. Maxwell will not have to add countless hours to her review. Defense counsel would like to send these hard drives to Ms. Maxwell for her to use in the MDC. We were informed by the MDC Legal Department that they are only permitted t