DOJ-OGR-00002260.jpg

521 KB

Extraction Summary

3
People
2
Organizations
2
Locations
3
Events
2
Relationships
0
Quotes

Document Information

Type: Legal document
File Size: 521 KB
Summary

This legal document is the second page of a letter dated January 8, 2021, from attorney Christian R. Everdell to Judge Alison J. Nathan. Everdell requests a 30-day extension for his client, Ms. Maxwell, to file a notice of appeal against the court's December 28, 2020 order denying her bail. The letter argues the extension would promote judicial efficiency and notes that the government objects to the request.

People (3)

Name Role Context
Alison J. Nathan Honorable (Judge)
Recipient of the letter.
Ms. Maxwell Client/Defendant
The subject of the legal proceedings, on whose behalf the letter is written to request an extension to appeal the den...
Christian R. Everdell Attorney
The author of the letter, representing Ms. Maxwell.

Organizations (2)

Name Type Context
COHEN & GRESSER LLP Law firm
The law firm of Christian R. Everdell, the author of the letter.
Court of Appeals Government agency
Mentioned as a venue for potential parallel proceedings.

Timeline (3 events)

2020-12-28
The Court issued an Order denying Ms. Maxwell's renewed motion for bail.
The Court Ms. Maxwell
2021-01-08
Filing of a request for a 30-day extension of time to file a notice of appeal.
Christian R. Everdell The Honorable Alison J. Nathan
2021-01-11
The deadline for Ms. Maxwell to file a notice of appeal if the extension is not granted.

Locations (2)

Location Context
The address of the law firm COHEN & GRESSER LLP.
Location of the law firm COHEN & GRESSER LLP.

Relationships (2)

Christian R. Everdell Professional (Attorney-Client) Ms. Maxwell
Christian R. Everdell of COHEN & GRESSER LLP is writing on behalf of Ms. Maxwell to request an extension for her appeal.
Ms. Maxwell Adversarial (Legal) the government
The letter states, 'We have conferred with the government and it objects to the requested extension,' indicating they are opposing parties in a legal matter.

Full Extracted Text

Complete text extracted from the document (1,376 characters)

Case 1:20-cr-00330-AJN Document 109 Filed 01/08/21 Page 2 of 2
The Honorable Alison J. Nathan
January 8, 2021
Page 2
A brief extension of the time to appeal would also promote judicial efficiency because a
third bail application may moot the need to appeal from the December 28 Order (or, in the event
the third application is denied, permit a consolidated appeal). Conversely, denying the extension
will require Ms. Maxwell to file a notice of appeal on January 11, 2021, which may lead to
unnecessary parallel proceedings in this Court and in the Court of Appeals.
We have conferred with the government and it objects to the requested extension.
For these reasons, we respectfully request that the Court grant a 30-day extension of time
under Rule 4(b)(4) of the Federal Rules of Appellate Procedure to file our notice of appeal of the
Court’s order denying Ms. Maxwell’s renewed motion for bail. (Dkt. 104, 106).¹
Sincerely,
/s/ Christian Everdell
Christian R. Everdell
COHEN & GRESSER LLP
800 Third Avenue, 21st Floor
New York, New York 10022
(212) 957-7600
cc: All Counsel of Record (By ECF)
¹ In the event this motion is denied (or not granted by the close of business on January 11, 2021),
Ms. Maxwell will file a notice of appeal to preserve her right to appeal the December 28, 2020
Order denying the renewed motion for bail (Dkt. 104, 106).
DOJ-OGR-00002260

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