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__ Case 1:20-cr-00330-PAE Document 422 Filed 11/08/21 Page 1 of 2
aN U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew’s Plaza
New York, New York 10007
November 8, 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, New York 10007
Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan:
The Government respectfully submits this letter in response to the Court’s Order dated
November 3, 2021, ordering the Government to docket a letter with a proposal from legal counsel
at the Metropolitan Detention Center (“MDC”) regarding what additional steps can be taken to
ensure that the defendant promptly receives her legal mail within the weeks leading up to trial
(Dkt. No. 412).
Legal counsel at the MDC informed the Government of the following: MDC mail room
staff will continue to pick up legal mail from the post office once every business day and follow
the processes outlined in the Government’s November 1, 2021 letter (Dkt. No. 403). As to
electronic discovery sent to legal counsel at the MDC, staff at the MDC’s warehouse will continue
to process and log the mail and the legal department will deliver the mail to the inmate. Legal
counsel at the MDC has indicated that they call or stop by the warehouse every day or every other
day to check for packages that have been delivered for the Legal Department.! Legal counsel at
' The Government will continue to inform legal counsel at the MDC when it sends a hard drive to
the attention of legal counsel, which goes to the MDC’s warehouse as outlined in the Government’s
October 15, 2021 letter (Dkt. No. 350).
DOJ-OGR-00006199