COHEN & GRESSER LLP

COHEN & GRESSER LLP October 1, 2020 BY EMAIL Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear 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. We have now had several phone calls and emails to discuss the problems with the discovery, but the problems still are not fixed. 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. That is simply not acceptable. In our previous letter, dated September 21, 2020, we outlined for you the numerous problems that Ms. Maxwell had been having with unreadable discovery files since she first began receiving the government's productions in the MDC in August 2020. This was a continuation of the same problem we identified for you in our letter, dated August 27, 2020, when we requested a new set of the discovery materials