From: Christian Everdell
From: Christian Everdell Cc: Subject: [EXTERNAL] RE: Follow-up Date: Fri, 15 Oct 2021 16:59:01 +0000 Inline-Images: image001.gif; image002.jpg Thanks for the clarification. As to your first point, we are aware of the requirements of Rule 12.2 and you have made your position on waiver clear. We do not intend to rely on any defense covered by the rule. If this becomes an issue later, you can certainly raise it with the Court. As to your second point, we cannot (and are under no obligation to) disclose our defense strategy. If you feel like you need to move in limine on this issue, you are certainly free to do so. Thanks, Chris From: Sent: Thursday, October 14, 2021 10:40 PM To: Subject: RE: Follow-up Hi Chris, Thanks for your email. On the first issue, we see that you filed a letter with the Court on the subject. On the second issue, we think there may be a bit of confusion. We're asking you two questions separately: 1. Do you intend to offer expert evidence relating
Summary
From: Christian Everdell Cc: Subject: [EXTERNAL] RE: Follow-up Date: Fri, 15 Oct 2021 16:59:01 +0000 Inline-Images: image001.gif; image002.jpg Thanks for the clarification. As to your first point, we are aware of the requirements of Rule 12.2 and you have made your position on waiver clear. We do not intend to rely on any defense covered by the rule. If this becomes an issue later, you can certainly raise it with the Court. As to your second point, we cannot (and are under no obligation to) disclose our defense strategy. If you feel like you need to move in limine on this issue, you are certainly free to do so. Thanks, Chris From: Sent: Thursday, October 14, 2021 10:40 PM To: Subject: RE: Follow-up Hi Chris, Thanks for your email. On the first issue, we see that you filed a letter with the Court on the subject. On the second issue, we think there may be a bit of confusion. We're asking you two questions separately: 1. Do you intend to offer expert evidence relating
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UNITED STATES DISTRICT COURT
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. x 20 Cr. 330 (AJN) MEMORANDUM IN SUPPORT OF GHISLAINE MAXWELL'S THIRD MOTION FOR RELEASE ON BAIL Bobbi C. Sternheim Law Offices of Bobbi C. Sternheim Christian R. Everdell COHEN & GRESSER LLP Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Attorneys for Ghislaine Maxwell EFTA00090990 INTRODUCTION Ghislaine Maxwell respectfully submits this Memorandum in Support of her Third Motion for Release on Bail. As Ms. Maxwell has stated on numerous occasions and reaffirms here: she has no intention or desire to leave this country. She is an American citizen, has lived in United States for 30 years, has strong family ties and the support of friends and family residing in this country. She wants nothing more than to remain in the United States under whatever conditions the Court deems necessary so that she can effectively prepare fo
UNITED STATES DISTRICT COURT
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. x 20 Cr. 330 (AJN) MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF HER RENEWED MOTION FOR BAIL Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP New York, NY 10022 Phone: Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Denver, CO 80203 Phone: Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim New York, NY 10011 Phone: Attorneys for Ghislaine Maxwell EFTA00094289 TABLE OF CONTENTS Page PRELIMINARY STATEMENT 1 ARGUMENT 7 I. Reconsideration of the Court's Bail Decision is Appropriate Under 18 U.S.C. § 3142(O 7 II. Ms. Maxwell Should Be Granted Bail Under the Proposed Strict Bail Conditions 10 A. Ms. Maxwell Has Deep Family Ties to the United States and Numerous Sureties to Support Her Bond 10 1. Ms. Maxwell is Devoted to Her Spouse and Stepchildren and Would Never Destroy Her Family By Leaving th
EFTA00011452
Court filings and motions: 38
The documents include court filings related to the cases of Jeffrey Epstein and Ghislaine Maxwell, focusing on issues such as the disclosure of victim identities, protective orders, and access to discovery materials. The filings demonstrate the legal strategies employed by both the prosecution and the defense in these high-profile cases.
To: Laura Mennin er tennin e
From: To: Laura Mennin er tennin e mflaw.com>, " " • (USANYS)" Cc: Jeff Pagliuca ipagliuca@hmflaw.com>, "Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)" <ceverdell@cohengresser.com>, 'BOBBI C STERNHEIM' <bcstemheim@mac.com> Subject: RE: US v. Maxwell - 20 Cr. 330 (MN) - Request to view evidence, highly confidential materials, scenes Date: Sat, 27 Mar 2021 22:38:06 +0000 Inline-Images: image001.jpg Counsel, Thank you for your email. Below please find our response. If this is acceptable to you, then we will proceed with arranging the logistics of having your client produced to 500 Pearl the week of April 12th and the week April 19th. We will also arrange for the FBI to transport evidence to 500 Pearl for review the week of April 12rh. Physical Evidence • It is not reasonable or feasible to insist that the FBI bring all physical evidence to 500 Pearl Street. That said, we are certainly willing to work with you to ensure that your client can revi
Court filings and letters: 30
The documents include a letter from the U.S. Attorney's Office regarding Jeffrey Epstein's foreign passport and court filings related to Ghislaine Maxwell's case, focusing on disputes over discovery materials and the disclosure of alleged victims' identities.
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