DOJ-OGR-00005263.pdf

Case 1:20-cr-00330-PAE Document 358 Filed 10/18/21 Page 4 of 4 The Honorable Alison J. Nathan October 18, 2021 Page 4 Maxwell had sufficient opportunity to review the disclosures or the opportunity to effectively review and discuss the production with counsel. Clearly, there has been insufficient time to prepare any additional filings to meet today's deadline, a concern previously raised with government counsel and the Court.2 Accordingly, Ms. Maxwell reserves the right to file additional/or supplemental motions in limine in response to the government's recent disclosure of Jencks Act, Giglio material and government exhibits, dated October 11, 2021. See 6/2/2021 Order (Dkt. 297) ("In addition, and as requested by the parties, the parties may bring issues to the Court's attention that arise after the deadline for motions in limine if the issues could not have been raised within the deadline set for in limine motions.") Your consideration is greatly appreciated. Respectfully Submitted, Jeffrey S. Pagliuca CC: Counsel of Record (via ECF) 2 In addition, Ms. Maxwell's counsel provided the government with encrypted hard drives to obviate the need for the government to encrypt the underlying files. Contrary to the defense's specific request, the government encrypted the files themselves necessitating two passcodes—one to open the hard drive and one to open the files—to access the documents each time we wish to review them. This two-step process has slowed the review process. DOJ-OGR-00005263