302 [DOJ-OGR-00004777—DOJ-OGR-00004779]

Case 1:20-cr-00330-PAE Document 302 Filed 06/16/21 Page1of3 oN U.S. Department of Justice plete, United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew’s Plaza New York, New York 10007 June 7, 2021 BY ECF The Honorable Alison J. Nathan United States District Court Souther 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 to provide an update regarding the defendant’s conditions of confinement at the Metropolitan Detention Center (“MDC”) pursuant to the Court’s Order dated December 8, 2020. (Dkt. No. 92). This update is based on information provided to the Government by MDC legal counsel regarding the conditions of the defendant’s confinement over the last two months. The defendant continues to receive more time to review discovery than any other inmate at the MDC. Specifically, the defendant is permitted to review her discovery thirteen hours per day, seven days per week. During the entirety of that time, the defendant still has access to both a desktop computer provided by the MDC and a laptop computer provided by the Government on which to review discovery. Also during those thirteen hours per day, the defendant may use the MDC desktop computer to send and receive emails with her attorneys. This discovery review takes place in a day room that is separate from the defendant’s assigned cell. Accordingly, the defendant continues to be permitted out of her cell from 7am to 8pm every day. While in the day room, the defendant continues to have exclusive access to the MDC desktop computer, the laptop, a television, a phone on which to place social or attorney calls, and a shower. The defendant is DOJ-OGR-00004777