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Discovery-Access Disputes in United States v. Maxwell

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tagstopic, southern-district-of-new-york, ghislaine-maxwell, criminal-discovery, metropolitan-detention-center

23 min read

InstitutionU.S. District Court for the Southern District of New York (Judge Alison J. Nathan), in United States v. Maxwell, 20 Cr. 330 (AJN)1
The starting documentA 3-page letter of October 1, 2020 from Maxwell’s defense firm to a government attorney, the third in a chain complaining that discovery files at the Metropolitan Detention Center (MDC) were unreadable; sent by email, not filed with the court23
The complaint reaches the courtFiled October 23, 2020: a letter recites the same chronology and adds a second complaint, that the government was delaying files from a prior Florida investigation45
The government’s answer, October 30, 2020Denies the accusations, reports more than 350,000 pages produced and 1.2 million more coming, and says of the MDC complaints specifically that “there is no need for an order”6
What the court actually ruledThree orders, on three narrower requests in the same family: denying without prejudice a broader access motion (Aug. 25, 2020); ordering production of the delayed Florida-investigation files by a fixed date (Nov. 18, 2020); and, over the Bureau of Prisons’ own objection, denying a request to take back weekend and holiday laptop access it had ordered (Feb. 2, 2021)789
Not located in this releaseAn order ruling on the October 23, 2020 letter’s specific request that the government be ordered to fix the readable-discovery problem and that MDC staff be ordered to let counsel pass Maxwell papers to review10

EFTA00013222, dated October 1, 2020, is a 3-page letter on Cohen & Gresser LLP letterhead, addressed by email to a government attorney whose name the production redacts, captioned “United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN).”2 It complains that “the government still has not provided a complete set of readable discovery materials to Ms. Maxwell in the MDC,” recites two prior letters on the same problem, and asks the government to build a laptop loaded with a verified-readable copy of the discovery and deliver it to Maxwell at the MDC, along with prompt access to seized photographs and to documents marked “Highly Confidential.”23 It is one side’s letter to opposing counsel, not a filing with the court, and states no relief the court could grant; nothing in it is a finding, and nothing about it establishes that discovery was in fact incomplete. Because a single unanswered letter is not an institution deciding anything, this page follows the same dispute into the parts of the record where a court did decide something.

The letter, and the two before it

The October 1 letter is the third in a sequence, not the first. Defense counsel first raised the problem in a letter of August 27, 2020, after Maxwell was unable to open a substantial number of files in the government’s first three productions; the same day, counsel proposed shortening file paths and switching from McAfee to on-board hard-drive encryption, and shipped two replacement drives.1112 A follow-up letter of September 21, 2020 lists specific Bates ranges of documents Maxwell still could not open across all three productions and demands a fully readable replacement set;1314 that letter also raised two further issues — access to documents marked “Highly Confidential” under the case’s protective order, and a set of MDC conditions-of-confinement complaints — that are outside what this page covers.1516 The October 1 letter recounts two more conference calls (September 22 and 29), a replacement hard drive delivered September 9 that fixed some but not all of the files, an MDC information-technology visit on October 7 that “did not fix the problem,” and a third government attempt at a full replacement production, made available to Maxwell on October 2, 2020.217 Read end to end, the letter’s own account is of an unresolved technical dispute between counsel, escalating letter by letter, with no ruling from anyone but the parties themselves on whether the government’s discovery obligations had in fact been met.

The complaint reaches the court, October 23, 2020

On October 23, 2020, Maxwell’s other defense firm, Haddon Morgan and Foreman, filed a letter with the court captioned “Response to the Government’s October 7, 2020 letter.”4 It reports that the October 2, 2020 production reached Maxwell only “yesterday afternoon, almost three weeks after the production date,” and that she “still cannot read all of the documents in the government’s prior productions.”18 Later in the same letter it restates the fuller MDC readability chronology from the October 1 letter — “the discovery that it has produced to Ms. Maxwell in the MDC thus far has been incomplete and portions are still unreadable” — and asks the court “to order the Government to address this problem immediately.”5 It separately reports that on a legal visit the same day, MDC guards required defense counsel to sit across from Maxwell rather than beside her and, after a call to the prosecutors, still would not let counsel pass her documents that required review rather than only a signature, and on that point asks the court “to order the BOP to allow defense counsel to pass legal papers to Ms. Maxwell for her review during prison visits.”19

The letter’s larger subject, however, is a separate complaint: that the government had promised at the case’s initial conference to review and produce “prior investigative files from another investigation in the Southern District of Florida,” described as “the core of the case,” and was now, in an October 7, 2020 letter, “abandoning the deadlines to which it already agreed.”4 It also argues that the “speaking” indictment and the discovery produced to date fail to identify an accuser, a date, or a specific act, and asserts that dozens of women who accused Epstein of misconduct in the earlier Florida investigation did not implicate Maxwell.1820 It further argues that the government had not produced material about the genesis of the 2007 non-prosecution agreement with Jeffrey Epstein or about meetings between accusers’ lawyers and prosecutors in 2016 — material the letter characterizes as exculpatory.21 This page does not evaluate that characterization; it is the defense’s own assertion, made to persuade a judge, not a finding.

The government’s answer, October 30, 2020

The government replied on October 30, 2020, calling the letter “an effort to preview again motions that the Court has already found to be premature” and casting the government’s own posture as transparent rather than obstructive.22 On the merits it reported more than 350,000 pages of Rule 16 discovery produced to date and a further production of over 1.2 million documents from Epstein’s seized devices then in preparation, and said the defense’s readability complaints concerned “only a subset of the hundreds of thousands of pages produced.”6 On the two MDC requests specifically, the government’s answer was that no order was needed: MDC counsel had “informed the Government that MDC staff has been instructed to allow defense counsel to pass papers,” and the technical work on readability was “already underway and remain[s] ongoing.”236 It also stated that Maxwell was already receiving “access to her discovery for approximately 13 hours per day.”6 This is the government’s own characterization, made in the same adversarial posture as the letter it answers; nothing here should be read as more than the two sides’ competing accounts of the same weeks.

What the court actually ruled

No order specifically resolving the October 23 letter’s two MDC requests appears in the docket sheet reproduced in this release.10 Three related orders do appear, on three narrower disputes within the same broader disagreement over Maxwell’s access to her own defense materials.

August 25, 2020 — the broader access motion, denied without prejudice. Before the readability letters began, Maxwell had already sought court intervention once. An August 10, 2020 letter motion asked the court to order the government to disclose immediately the identities of the three alleged victims referenced in the indictment, and to order the Bureau of Prisons to release Maxwell into the general population with increased discovery access.7 On August 25, 2020, the court denied both requests without prejudice, directed the parties to confer on a disclosure schedule after the close of discovery, and ordered the government to submit status reports every 90 days on Maxwell’s “access to legal materials and ability to communicate with defense counsel.”7 The September 21, 2020 letter invokes this order directly as the basis for again seeking the court’s help if access problems continued.24

November 18, 2020 — the Florida-files dispute, decided in Maxwell’s favor on timing. The larger dispute in the October 23 letter — delay in producing the Southern District of Florida investigative files — had its own separate track on the docket, running from an October 6, 2020 government letter requesting delayed disclosure through defense and government replies on October 14 and 20.8 On November 18, 2020, the court found no dispute that the materials would eventually be produced, only over timing, and ruled that the government’s proposal to wait until eight weeks before trial was “insufficient”; it ordered the materials produced by March 12, 2021.8

January–February 2021 — the laptop, and a Bureau of Prisons objection overruled. By November 18, 2020, separately from the litigated Florida-files dispute, the government had in fact delivered what the October 1 letter first asked for: a laptop loaded with Maxwell’s discovery, for her exclusive use at the MDC.25 By January 2021 the dispute had narrowed to a new, more specific question — whether that access extended to weekends and holidays. On January 14, 2021, Maxwell’s counsel wrote asking for weekend and holiday laptop access; the court granted the unopposed request the next day.26 MDC legal counsel then wrote the court on January 25, 2021 asking it to vacate that order, stating that MDC “was not given the opportunity to object” and that Maxwell already had the laptop “thirteen (13) hours per day, five (5) days per week” plus weekend access to MDC’s own discovery computers.27 The government’s own letter of February 1, 2021 took a middle position — no objection to the extra access, but deference to MDC’s judgment on how to manage the facility — while confirming that the laptop had been “hand delivered” on November 18, 2020 and that Maxwell already had more review time than any other MDC inmate.2528 On February 2, 2021, the court denied the Bureau of Prisons’ request to vacate its own order, over that objection.9

What was not resolved in this release

This page searched the phrases “unreadable discovery” and “readable discovery” across the whole corpus, and the docket sheet reproduced in this release, for any order between October 23, 2020 and the close of pretrial motions that names the two specific requests in the October 23 letter — an order compelling readable discovery and an order on MDC staff passing Maxwell documents to review.10 No order matching either request is among the results. Most of what the two searches return are the letters described on this page and their duplicate copies, but they also surface a document not otherwise cited on this page: a memorandum filed December 14, 2020 in support of Maxwell’s renewed motion for bail, stating that “the fourth and fifth productions, which were produced after the defense alerted the government to these problems, contained some of the same technical problems and included a significant number of unreadable documents,” and that as a result “Ms. Maxwell has not had access to a complete set of readable discovery for over four months.”29 That is Maxwell’s own assertion, made to support a bail application rather than a discovery motion — not a court finding, and this page does not evaluate it — but it is her own account, unrebutted in this release, that the readability problem the October 1 and October 23 letters describe persisted beyond the productions those letters cover. No order addressing it appears among the search results either.

That the two MDC requests reached no order is consistent with the government’s own October 30 position that no order was needed because the underlying problems were already being addressed informally, and with the fact that a government-provided laptop was in Maxwell’s hands by November 18, 2020 — but this page did not locate a document that says the court agreed with that position, or that the parties told the court the problem was resolved. This is reported as an absence in this release, not as a claim that no such order exists.

Cited in

Ghislaine Maxwell; SDNY Prosecution Memoranda in the Epstein and Maxwell Investigations.

Footnotes

  1. Docket sheet of United States v. Maxwell, 20 Cr. 330 (AJN), as of March 2021, reproduced within the Second Circuit’s record on Maxwell’s bail appeal, No. 21-770. This page cites the copy at EFTA02824716 (dataset 12), a 304-page composite production that contains this same 24-page docket sheet twice; citations below use the first occurrence, at pp. 3–26 of the 304-page document. A second copy, stamped DOJ-OGR-00000838, is already cited elsewhere on this wiki, e.g. on Ghislaine Maxwell, but could not be rendered for this page (the release’s PDF path for dataset 99 returns HTTP 403); EFTA02824716 was confirmed to carry identical text at every page checked and was read from the page images at 300 dpi instead. https://epstein-data.com/EFTA02824716 ↩

  2. EFTA00013222, p. 1 of 3 (“COHEN & GRESSER LLP”; “October 1, 2020”; “BY EMAIL”; “Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)”; “We write once again to express our dissatisfaction that the government still has not provided a complete set of readable discovery materials to Ms. Maxwell in the MDC… It is now over five weeks since the August 21 discovery deadline set by the court and the government still has not met its discovery obligations.”; addressee name redacted at the image; read from the page image at 300 dpi). https://epstein-data.com/EFTA00013222 ↩ ↩2 ↩3 ↩4

  3. EFTA00013222, p. 3 of 3 (“we reiterate the request… that the government create a laptop computer… and then provide that laptop immediately to Ms. Maxwell in the MDC”; renewed requests for access to the non-nude images and to Highly Confidential documents; signature block and cc line redacted at the image; read from the page image at 300 dpi). https://epstein-data.com/EFTA00013222 ↩ ↩2

  4. EFTA00100925 (Case 1:20-cr-00330-AJN, Document 66, filed 10/23/20), p. 1 of 7 (“Response to the Government’s October 7, 2020 letter”; the government’s promise to review and produce “prior investigative files from another investigation in the Southern District of Florida,” characterized as “the core of the case”; “Summer is gone, Winter is coming, and the Government has failed to make good on its promises.”; read from the page image at 300 dpi, which confirms the caption reads “(AJN),” not the machine text’s “(MN)”). https://epstein-data.com/EFTA00100925 ↩ ↩2 ↩3

  5. EFTA00100925, p. 6 of 7 (“The Government Has Not Complied with Its Discovery Obligations to Ms. Maxwell in the MDC.”; “the discovery that it has produced to Ms. Maxwell in the MDC thus far has been incomplete and portions are still unreadable”; the August 27 through October 9, 2020 chronology; “Accordingly, we ask the Court to order the Government to address this problem immediately.”; read from the page image at 300 dpi). https://epstein-data.com/EFTA00100925 ↩ ↩2

  6. EFTA02829650, p. 4 of 4 (“the technical issues have, at their worst, impacted the defendant’s ability to view only a subset of the hundreds of thousands of pages produced to her”; “the defendant has access to her discovery for approximately 13 hours per day and therefore receives more time to review her discovery than any other inmate in the MDC”; “Because those efforts are already underway and remain ongoing, there is no need for an order directing them.”; “there is no need for an order to address this issue”; MDC staff “instructed to allow defense counsel to pass papers to their client for her to review during visits”; read from the page image at 300 dpi). https://epstein-data.com/EFTA02829650 ↩ ↩2 ↩3 ↩4

  7. EFTA02824716, p. 13 of 304 (docket entry 49, August 25, 2020: “MEMORANDUM OPINION AND ORDER: denying without prejudice 38 LETTER MOTION… First, the Defendant seeks an order directing the Government to disclose to defense counsel immediately the identities of the three alleged victims referenced in the indictment. Second, the Defendant seeks an order directing the Bureau of Prisons… to release the Defendant into the general population and to provide her with increased access to the discovery materials… Defendant’s requests are DENIED without prejudice… The Government is hereby ORDERED to submit written status updates every 90 days…”; read from the page image at 300 dpi). https://epstein-data.com/EFTA02824716 ↩ ↩2 ↩3

  8. EFTA02824716, p. 15 of 304 (docket entries 60, 62–67, 73: the government’s October 6, 2020 “Request to Delay Disclosure” (Dkt. 60), briefing through October 20 (Dkt. 65), the defense’s October 23 letter (Dkt. 66) and the government’s October 30 reply (Dkt. 67), and the November 18, 2020 ruling: “There is no dispute that the materials referenced in the Government’s letter will be turned over to the defense… The only dispute, then, relates to the timing… the Government’s proposal to delay disclosure until 8 weeks in advance of trial is insufficient… the Government shall produce the referenced materials, which are not voluminous, to the defense by March 12, 2021.”; read from the page image at 300 dpi). https://epstein-data.com/EFTA02824716 ↩ ↩2 ↩3

  9. EFTA00028163, p. 1 of 2, court endorsement quoted in the citation immediately above; the same order is docketed at entry 131 on the docket sheet reproduced at EFTA02824716, p. 22 of 304 (“MEMO ENDORSEMENT… the Court hereby DENIES the BOP’s request to vacate the Order. SO ORDERED. (Signed by Judge Alison J. Nathan on 2/2/2021)”; read from the page image at 300 dpi). https://epstein-data.com/EFTA00028163 ↩ ↩2

  10. Full-text search of the corpus (run 2026-09-07) for the phrases “unreadable discovery” and “readable discovery.” “Unreadable discovery” returns 11 hits, all on the letters described on this page and their duplicate copies: EFTA00013222 (this page’s starting document) is also stamped EFTA00068334; the October 23, 2020 letter (EFTA00100925) is also stamped EFTA00097829; stamped EFTA00076283; stamped EFTA00081937; stamped EFTA00066546; stamped EFTA02829643; and stamped DOJ-OGR-00001805 — plus two hits the earlier version of this note omitted: EFTA00073193, the August 27, 2020 email already cited above at note “073193p1”, and stamped EFTA00073188, a government-side internal forward of that same email and attached letter, adding two lines of instruction about shortening file names before loading the replacement hard drive, not otherwise cited on this page. “Readable discovery” returns 26 hits: the same letters and duplicate stamps (the phrase recurs on two printed pages of the six- and seven-page copies), the docket sheet at EFTA02824716 and DOJ-OGR-00000838 already cited at note “docket” above — each of which, at p. 302 of its 304 pages, also contains a copy of the memorandum quoted at note “097p43” above, embedded there as part of the same Second Circuit appellate record — and eight further copies of that same memorandum, stamped DOJ-OGR-00001973; stamped EFTA00065716 (the copy cited above); stamped EFTA00094289; stamped EFTA02829952 (each p. 43 of 45); stamped EFTA00154512 (p. 43 of 45); stamped DOJ-OGR-00019829; stamped EFTA02843657 (each p. 229 of 231); and stamped EFTA00093044 (p. 215 of 382). No order is among the results of either search. The docket sheet reproduced at EFTA02824716 was read in full from pp. 14–26 of 304 (docket entries 54 through 159, October 2020 through February 2021); no entry in that range is captioned as an order on document readability or on MDC staff passing Maxwell papers for review. This is a report of the searches run and their results, not a claim that no such order exists. ↩ ↩2 ↩3

  11. EFTA00013225, p. 2 of 10 (the August 27, 2020 conference call and same-day follow-up letter proposing shortened file paths and on-board hard-drive encryption, and shipment of two replacement hard drives). https://epstein-data.com/EFTA00013225 ↩

  12. EFTA00073193, p. 1 of 1 (email of August 27, 2020, 20:59 UTC, from Christian Everdell to a redacted government recipient, subject “Letter re: Discovery,” attaching “2020.08.27_Letter to_Government_re_Unreadable_Discovery.PDF” and confirming two replacement hard drives shipped the same day). https://epstein-data.com/EFTA00073193 ↩

  13. EFTA00013225, p. 3 of 10 (Bates-range list of unreadable documents from Production 1 and the start of Production 2, headed “September[,] Page 3”). https://epstein-data.com/EFTA00013225 ↩

  14. EFTA00013225, p. 4 of 10 (continuation of the Bates-range list through Production 3; “It is the responsibility of the government, not the defense, to ensure that Ms. Maxwell has a complete set of the discovery that she can review in the MDC.”). https://epstein-data.com/EFTA00013225 ↩

  15. EFTA00013225, p. 1 of 10 (“COHEN & GRESSER LLP”; “September 21, 2020”; “We write to address three issues” — incomplete discovery production, access to Highly Confidential documents, and conditions of confinement). https://epstein-data.com/EFTA00013225 ↩

  16. EFTA00013225, pp. 5–7 of 10 (requests concerning access to “Highly Confidential” documents and a series of MDC conditions-of-confinement complaints — a writing surface, cell placement, body scans, commissary access, food, and mail delivery — outside what this page covers). https://epstein-data.com/EFTA00013225 ↩

  17. EFTA00013222, p. 2 of 3 (the September 22 and 29, 2020 conference calls; the October 7, 2020 MDC IT visit that “did not fix the problem”; the third replacement production, “provided this afternoon”; read from the page image at 300 dpi). https://epstein-data.com/EFTA00013222 ↩

  18. EFTA00100925, p. 2 of 7 (“Furthermore, the Government’s production of discovery to Ms. Maxwell in the MDC has been deficient and inadequate. For example, Ms. Maxwell only received the Government’s October 2, 2020 production yesterday afternoon, almost three weeks after the production date, and she still cannot read all of the documents in the government’s prior productions.”; “including three letters, three conference calls, numerous emails, and countless hours of time and effort”; “The ‘speaking’ indictment in this case is remarkable because it fails to identify an accuser, a specific date that Ms. Maxwell is alleged to have committed a crime, or when anything in furtherance of any alleged conspiracy occurred.”; read from the page image at 300 dpi). https://epstein-data.com/EFTA00100925 ↩ ↩2

  19. EFTA00100925, p. 7 of 7 (“The BOP, for their part, has only exacerbated these problems”; the same-day legal visit where MDC guards would not let counsel sit beside Maxwell or pass her documents for review rather than only for signature; “Accordingly, we ask the Court to order the BOP to allow defense counsel to pass legal papers to Ms. Maxwell for her review during prison visits.”; read from the page image at 300 dpi). https://epstein-data.com/EFTA00100925 ↩

  20. EFTA00100925, p. 3 of 7 (continuing the indictment-specificity argument with case citations; “The Discovery Provided to Date Contains No Corroborating Information and Omits Exculpatory Evidence”; “We know, for example that dozens of women accused Jeffrey Epstein of misconduct and that the Government interviewed these women in connection with the Florida proceedings. None of these women implicated Ms. Maxwell in any wrongdoing, nor was Ms. Maxwell accused or involved in the Florida investigation.”; read from the page image at 300 dpi). https://epstein-data.com/EFTA00100925 ↩

  21. EFTA00100925, p. 4 of 7 (“The Government has not provided any information about the genesis of the Non-Prosecution Agreement (‘NPA’) that the Government entered into with Jeffrey Epstein in 2007.”; “lawyers for the accusers met with the Government in 2016… Neither the fact of these meetings nor the content has been disclosed. This is significant exculpatory information…”; read from the page image at 300 dpi). https://epstein-data.com/EFTA00100925 ↩

  22. EFTA02829650 (Case 1:20-cr-00330-AJN, Document 67, filed 10/30/20), p. 1 of 4 (“For all of its innuendo and accusations, the Defense Letter is at base an effort to preview again motions that the Court has already found to be premature”; more than 350,000 pages of Rule 16 discovery produced to date and a further production of over 1.2 million documents in preparation; read from the page image at 300 dpi). https://epstein-data.com/EFTA02829650 ↩

  23. EFTA02829650, p. 3 of 4 (the government’s account of its efforts on the Florida FBI files and the Prosecution Team’s review of them). https://epstein-data.com/EFTA02829650 ↩

  24. EFTA00013225, p. 9 of 10 (“In her August 25, 2020 Opinion and Order, Judge Nathan stated that if Ms. Maxwell is not being provided sufficient access to the discovery materials ‘so that she can meaningfully participate in the preparation of her defense,’ defense counsel may seek intervention by the Court. (Dkt. 49 at 2).”). https://epstein-data.com/EFTA00013225 ↩

  25. EFTA00082140, p. 1 of 2 (letter of the U.S. Attorney’s Office, SDNY, dated February 1, 2021: “While the Government has no objection to the defendant’s request for additional laptop access, the Government also generally defers to the MDC regarding how it manages its inmate population.”; “Because the defendant continued to complain that she was unable to review certain discovery files on the desktop computer, the Government agreed to provide a laptop for the defendant to use in her review of discovery. On November 18, 2020, the Government hand delivered the laptop to the MDC for the defendant’s exclusive use.”; discovery in the case “totals more than two million pages”; read from the page image at 300 dpi). https://epstein-data.com/EFTA00082140 ↩ ↩2

  26. EFTA02824716, p. 21 of 304 (docket entries 115–116: “01/14/2021 LETTER by Ghislaine Maxwell… re: Laptop Access”; “01/15/2021 MEMO ENDORSEMENT… 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.”; read from the page image at 300 dpi). https://epstein-data.com/EFTA02824716 ↩

  27. EFTA00028163 (Case 1:20-cr-00330-AJN, letter of the Federal Bureau of Prisons, Metropolitan Detention Center, dated January 25, 2021, electronically filed February 2, 2021 as docket entry 131), p. 1 of 2 (“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.”; “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.”; the court’s endorsement is printed on the same page: “Having considered the request submitted by the Bureau of Prisons… as well as the Government’s and the Defendant’s responses, Dkt. Nos. 129, 130, the Court hereby DENIES the BOP’s request to vacate the Order. SO ORDERED.”; signed by Judge Alison J. Nathan, dated 2/2/21; read from the page image at 300 dpi). https://epstein-data.com/EFTA00028163 ↩

  28. EFTA00082140, p. 2 of 2 (“the BOP was already affording the defendant access to the laptop for some 65 hours a week, and the BOP was further providing weekend access to a desktop computer”; read from the page image at 300 dpi). https://epstein-data.com/EFTA00082140 ↩

  29. EFTA00065716 (Case 1:20-cr-00330-AJN, Document 97, filed 12/14/20, “MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF HER RENEWED MOTION FOR BAIL”), p. 43 of 45 (“In addition, the fourth and fifth productions, which were produced after the defense alerted the government to these problems, contained some of the same technical problems and included a significant number of unreadable documents… As a result, Ms. Maxwell has not had access to a complete set of readable discovery for over four months.”; footnote 13 on the same page: the laptop delivered November 18, 2020 “believed would remedy the issues with unreadable documents,” but “It is too early to tell whether the new laptop and hard drive will solve all of the technical problems,” with review access then limited to “8am-5pm, five days a week”; read from the page image at 300 dpi, as was p. 1 of 45 for the caption and title). This is one of at least ten copies of the same 45-page memorandum found in the release; see note “absence” below for the others. https://epstein-data.com/EFTA00065716 ↩

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