This document is a response from Jeffrey S. Pagliuca, representing Ghislaine Maxwell, addressing the Government's failure to produce discovery materials in a timely and accessible manner. It highlights issues with the Government's handling of discovery, including delays, incomplete and unreadable documents, and lack of exculpatory evidence. The response criticizes the Government's redefinition of its discovery obligations and the impact on Maxwell's ability to prepare her defense. It also addresses logistical issues faced by Maxwell in reviewing discovery materials while detained.
documents/EFTA00097829.pdf
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