DOJ-OGR-00004734.jpg

557 KB

Extraction Summary

3
People
3
Organizations
2
Locations
1
Events
1
Relationships
2
Quotes

Document Information

Type: Legal correspondence / letter to the court
File Size: 557 KB
Summary

A legal letter dated May 28, 2021, from attorney Christian R. Everdell of Cohen & Gresser LLP to Judge Alison J. Nathan regarding the case United States v. Ghislaine Maxwell. The letter informs the court that the defense is filing an Omnibus Reply Memorandum under seal because it contains confidential discovery information governed by a protective order, allowing the government time to propose redactions before public filing.

People (3)

Name Role Context
Christian R. Everdell Attorney
Defense attorney for Ghislaine Maxwell; author of the letter.
Alison J. Nathan Judge
United States District Court Judge; recipient of the letter.
Ghislaine Maxwell Defendant
The client represented by Cohen & Gresser LLP in the criminal case.

Organizations (3)

Name Type Context
Cohen & Gresser LLP
Law firm representing Ghislaine Maxwell.
United States District Court, Southern District of New York
The court handling the case.
Department of Justice (DOJ)
Implied by the Bates stamp 'DOJ-OGR-00004734'.

Timeline (1 events)

2021-05-28
Filing of Omnibus Reply Memorandum in Support of Ms. Maxwell’s Supplemental Pretrial Motions Relating to the S2 Superseding Indictment.
Southern District of New York

Relationships (1)

Christian R. Everdell Attorney-Client Ghislaine Maxwell
Letter states 'On behalf of our client, Ghislaine Maxwell'

Key Quotes (2)

"The reply memorandum contains Confidential Information produced in discovery that is governed by paragraph 15 of the Protective Order (Dkt. 36)."
Source
DOJ-OGR-00004734.jpg
Quote #1
"we will submit the reply memorandum by email to the Court and the government under seal... to give the government the opportunity to propose and justify any redactions it deems necessary."
Source
DOJ-OGR-00004734.jpg
Quote #2

Full Extracted Text

Complete text extracted from the document (1,526 characters)

Case 1:20-cr-00330-PAE Document 296 Filed 05/28/21 Page 1 of 1
C&G COHEN & GRESSER LLP
800 Third Avenue
New York, NY 10022
+1 212 957 7600 phone
www.cohengresser.com
Christian R. Everdell
+1 (212) 957-7600
ceverdell@cohengresser.com
May 28, 2021
VIA ECF
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:
On behalf of our client, Ghislaine Maxwell, we will be filing our Omnibus Reply Memorandum in Support of Ms. Maxwell’s Supplemental Pretrial Motions Relating to the S2 Superseding Indictment.
The reply memorandum contains Confidential Information produced in discovery that is governed by paragraph 15 of the Protective Order (Dkt. 36). Accordingly, pursuant to our prior practice, we will not file the reply memorandum on the public docket until we are instructed to do so by the Court. Instead, we will submit the reply memorandum by email to the Court and the government under seal—pursuant to Rule 2(B) of the Court’s individual rules of criminal practice—to give the government the opportunity to propose and justify any redactions it deems necessary.
Please contact us with any questions. Your consideration is greatly appreciated.
Respectfully submitted,
/s/ Christian R. 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 (via email)
DOJ-OGR-00004734

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