No issues from me. Thanks.

Sent from my iPhone

On Dec 30, 2020, at 9:38 PM,

This seems fine to me.

On Dec 30, 2020, at 7:38 PM,

This all appears accurate to me and seems fine to file. Any issues from your perspective?



Subject: FW: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera

Hey everyone: Here's the latest draft of our letter and declaration on this issue. We are still confirming a few things, but they shouldn't impact the substance of the Maxwell discussion. There is also a chance that there's a separate declaration from the MDC; if there is, it should contain the same substance re: Maxwell that's in the attached draft.

Our response is due tomorrow. I'm generally around later this evening or tomorrow if there's anything you'd like to discuss.

Thanks very much.



EFTA00099906



Subject: RE: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera

: We are in the process of finalizing our response to the Maxwell/Rivera issue. We intend to explain that the discovery and counsel access accommodations that have been provided to Maxwell and Rivera, respectively, result from the specific circumstances of their cases, the specific requests of their lawyers, and their individual housing circumstances. On all of these factors, there are several important differences, including:

- The Maxwell case has multiple times more discovery than the Rivera case. Hence, the need for such expanded discovery access is greater in the Maxwell case.

- At the MDC, Maxwell has a unique housing situation, as she is in protective custody outside the general population. She therefore has sole access to a room to use a computer and phone for approximately 13 hours a day. Rivera, by contrast, is housed in the general population.

- There are approximately 80 other inmates at the MCC in Rivera's unit that use the same VTC room for court appearances, probation interviews, and attorney meetings. By contrast, Maxwell shares access to the MDC VTC room with substantially fewer inmates. The MDC can therefore provide 15 hours of VTC meetings with her attorneys without compromising access for other MDC inmates. The same is not true for Rivera at the MCC.

Going forward, even though Rivera's counsel have asked (and the Court has ordered) that Rivera receive three hours of laptop access each day, the MCC is now leaving the laptop with him all day long, and only takes it back at night to charge it. Therefore, the MCC is now providing the same amount of electronic discovery access to Rivera that Maxwell receives at the MDC.

As for providing Rivera with up to 15 hours of VTC access, we will explain that doing so will compromise access for other inmates. If defense counsel expresses a need for additional time, the MCC will continue to find ways to accommodate those requests as best as they can.

Please let me know if you have any questions or would like to discuss this further.



Subject: RE: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera

Thanks, . Can you keep me posted on what we think will be the substance of the draft declaration when you know (that is, before we are submitting anything on 12/31)? And how much of this is attributable to differences between MCC and MDC, as well as specific differences in their housing situations?



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Sent: Monday, December 21, 2020 4:35 PM