COHEN & GRESSER LLP
a COHEN & GRESSER LLP Mark S. Cohen Christian R. Evendell =EL December 4, 2020 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 (AJN) Dear Judge Nathan: Per the Court's order (Dkt. 81), the parties have conferred regarding the briefing schedule for Ghislaine Maxwell's renewed motion for release on bail. The defense respectfully requests that the hearing take place before the holidays and the government is amenable to that schedule. Accordingly, the parties propose the following briefing schedule: Defense submission: Government response: Defense reply due: Hearing: December 7, 2020 December 16, 2020 December 18, 2020 December 21, 2020 (subject to the Court's availability) Per the Court's order, the defense will send our submissions to the Court under seal on the dates mentioned above and will include a proposed redacted version of
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a COHEN & GRESSER LLP Mark S. Cohen Christian R. Evendell =EL December 4, 2020 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 (AJN) Dear Judge Nathan: Per the Court's order (Dkt. 81), the parties have conferred regarding the briefing schedule for Ghislaine Maxwell's renewed motion for release on bail. The defense respectfully requests that the hearing take place before the holidays and the government is amenable to that schedule. Accordingly, the parties propose the following briefing schedule: Defense submission: Government response: Defense reply due: Hearing: December 7, 2020 December 16, 2020 December 18, 2020 December 21, 2020 (subject to the Court's availability) Per the Court's order, the defense will send our submissions to the Court under seal on the dates mentioned above and will include a proposed redacted version of
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Defense attorney Christian R. Everdell requests that the court order the MDC to accept two hard driv...
Defense attorney Christian R. Everdell requests that the court order the MDC to accept two hard drives containing non-Highly Confidential discovery materials for Ghislaine Maxwell's use. The hard drives are organized in a user-friendly format, and the government does not object to the request. The MDC Legal Department has expressed concerns and is given the opportunity to note objections.
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Christian R. Everdell of Cohen & Gresser LLP declares that the firm is withdrawing as co-counsel for Ghislaine Maxwell with her consent, as Markus Moss PLLC has taken over her representation for the government's motion to unseal grand jury transcripts. Cohen & Gresser LLP represented Maxwell during her trial and sentencing but not in her appellate proceedings. The firm will share its files with Markus Moss PLLC upon request.
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Ghislaine Maxwell's defense team files a motion to suppress evidence obtained from a government subpoena and to dismiss Counts Five and Six of the indictment, citing the Due Process Clause. The motion is supported by a memorandum of law and exhibits. The defense attorneys representing Maxwell are listed, along with their contact information.
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The documents include court filings related to the cases of Ghislaine Maxwell and Jeffrey Epstein. The first filing concerns the scheduling of Maxwell's arraignment and bail hearing, while the second is related to Epstein's bail motion and financial disclosure.
Court Filing - Letter to Judge: Case1:20-cr-03320-AJN Document 292 Filed 08/27/20 Page 20 of 1164
The defense attorneys for Ghislaine Maxwell request a protective order from Judge Alison J. Nathan to govern the handling of discovery materials. The parties have reached agreement on most provisions but remain at odds over restrictions on government witnesses and the disclosure of alleged victim identities.
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