DOJ-OGR-00007169.pdf

--- Page 1 --- **Case 1:20-cr-00330-PAE** **Document 465** **Filed 11/15/21** **Page 118 of 127** LB15max4 think the defense is well equipped to print those materials and meet with the defendant in person about it as they have been doing. They can certainly discuss those documents in the video conferences that they're having with the defendant. Our understanding is that this defense team has a large amount of access to video conferencing sessions with this defendant and so when the defense receives those materials, they're certainly free to review those with the defendant in real-time in their sessions. And so, we are taking every step that we can to ensure that the defense and the defendant have those materials but we think those steps are all that is required here and certainly more than is necessary to make sure the defendant is apprised of those materials in anticipation of trial. THE COURT: As to the steps, if you have a new submission we are talking about newly produced 3500 material, limited volume; correct, Ms. Moe? MS. MOE: Yes, your Honor. THE COURT: And you are going to send that by FedEx -- so overnight -- to the facility in each instance, correct? MS. MOE: Yes, your Honor. THE COURT: And you alert BOP counsel, MDC Legal counsel that something is coming for Ms. Maxwell so they can be on alert. Do you get indication back from legal counsel that it's been received and delivered? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007169