COHEN & GRESSER LLP

OG COHEN & GRESSER LLP Mark S. Cohen Christian R Everdell November 25, 2020 TO BE FILED UNDER SEAL VIA EMAIL (SUBMITTED PURSUANT TO SECTION 2(3) OF JUDGE NATHAN'S INDIVIDUAL PRACTICES IN CRIMINAL CASES) The Honorable Alison J. Nathan United States District Court Southern District of New York 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Judge Nathan: BOO Thad Avenue New Yak, NY 10022 +1 212 957 7600 phone oeww.cohengesser cool On behalf of our client, Ghislaine Maxwell, we plan to file a Renewed Motion for Release on Bail (the "Motion") and respectfully request an in camera conference, with all counsel present, to address the appropriate procedures for the filing and consideration of the Motion. For the reasons explained below, we intend to request, pursuant to Fed. R. Crim. P. 49.1(d), that the Court permit the filing of portions of the Motion and certain supporting materials under seal and require that any