As for the defendant’s complaint that he no longer has access to Google Docs, it is plainly reasonable that this means of preparation is no longer available to him. The Court was reluctant to give the defendant access to Google Docs even on pretrial release (Feb. 17, 2023 Tr. at 15-17), but permitted access after defense counsel insisted it was necessary for trial preparation. It was this very access that the defendant exploited to curate what he considered embarrassing material about Caroline Ellison that he leaked to the New York Times. (Aug. 11, 2023 Tr. at 7). It defies logic and common sense that such access would be granted a second time, where BOP policy does not permit it generally, and where the defendant has abused this tool specifically. While the defendant may prefer to create and relay his work product by other methods that were available to him on pretrial release, he has not established that he would be unable to communicate through a combination of more than ten legal and non-legal staff members. Rather than taking advantage of every avenue available to review discovery on the eve of trial after having seven months to prepare without restrictions, the defendant appears uninterested in participating in any form of review unless it meets his precise requests, including access to the very application he previously exploited. Contrary to counsel’s baseless assertion, the failure for the BOP and the USMS to accommodate the defendant’s most preferred means
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