DOJ-OGR-00001972.jpg
629 KB
Extraction Summary
4
People
3
Organizations
2
Locations
1
Events
2
Relationships
2
Quotes
Document Information
Type:
Legal correspondence / cover letter
File Size:
629 KB
Summary
This document is a legal cover letter dated December 8, 2020, from attorneys Mark Cohen and Christian Everdell to Judge Alison Nathan regarding the case United States v. Ghislaine Maxwell. The attorneys are submitting a Renewed Motion for Bail under seal, providing both an unredacted version for the court and a redacted version for public filing to protect privacy and confidential financial information. The document references previous correspondence and protective orders governing discovery materials.
People (4)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant / Client |
Subject of the renewed motion for bail.
|
| Alison J. Nathan | Judge |
Recipient of the letter; presiding judge in United States District Court SDNY.
|
| Mark S. Cohen | Attorney |
Defense counsel for Ghislaine Maxwell; partner at Cohen & Gresser LLP.
|
| Christian R. Everdell | Attorney |
Defense counsel for Ghislaine Maxwell; signer of the letter.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| Cohen & Gresser LLP |
Defense counsel firm representing Ghislaine Maxwell.
|
|
| United States District Court Southern District of New York |
Venue for the case.
|
|
| DOJ |
Department of Justice (implied by Bates stamp DOJ-OGR).
|
Timeline (1 events)
2020-12-08
Submission of Ghislaine Maxwell's Renewed Motion for Bail
Southern District of New York
Locations (2)
| Location | Context |
|---|---|
|
Address of the United States District Court SDNY.
|
|
|
Address of Cohen & Gresser LLP.
|
Relationships (2)
Letter states 'On behalf of our client, Ghislaine Maxwell'
Letter states 'On behalf of our client, Ghislaine Maxwell'
Key Quotes (2)
"we respectfully submit under seal two versions of the Memorandum of Ghislaine Maxwell in Support of Her Renewed Motion for Bail"Source
DOJ-OGR-00001972.jpg
Quote #1
"The proposed redactions are based on the following: (1) privacy concerns... and (2) the Motion’s reference to, and discussion of, Confidential Information, including financial documents"Source
DOJ-OGR-00001972.jpg
Quote #2
Full Extracted Text
Complete text extracted from the document (1,709 characters)
Case 1:20-cr-00330-AJN Document 96 Filed 12/14/20 Page 1 of 1
C&G
COHEN & GRESSER LLP
800 Third Avenue
New York, NY 10022
+1 212 957 7600 phone
www.cohengresser.com
COHEN & GRESSER LLP
800 Third Avenue
New York, NY 10022
+1 212 957 7600 phone
www.cohengresser.com
Mark S. Cohen
Christian R. Everdell
+1 (212) 957-7600
mcohen@cohengresser.com
ceverdell@cohengresser.com
Christian R. Everdell
+1 (212) 957-7600
mcohen@cohengresser.com
ceverdell@cohengresser.com
December 8, 2020
TO BE FILED UNDER SEAL
VIA EMAIL (SUBMITTED PURSUANT TO SECTION 2(B)
OF JUDGE NATHAN’S INDIVIDUAL PRACTICES IN CRIMINAL CASES)
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
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, and pursuant to the Court’s order (Dkt. 89),
we respectfully submit under seal two versions of the Memorandum of Ghislaine Maxwell in
Support of Her Renewed Motion for Bail (the “Motion”) and accompanying exhibits: an
unredacted original to be kept under seal and a version for public filing with proposed narrowly
tailored redactions. The proposed redactions are based on the following: (1) privacy concerns, as
articulated in our letters of November 25, 2020 (Dkt. 86) and November 30, 2020 (Dkt. 87); and
(2) the Motion’s reference to, and discussion of, Confidential Information, including financial
documents and other materials produced in discovery and governed by paragraph 15 of the
Protective Order (Dkt. 36).
we respectfully submit under seal two versions of the Memorandum of Ghislaine Maxwell in
Support of Her Renewed Motion for Bail (the “Motion”) and accompanying exhibits: an
unredacted original to be kept under seal and a version for public filing with proposed narrowly
tailored redactions. The proposed redactions are based on the following: (1) privacy concerns, as
articulated in our letters of November 25, 2020 (Dkt. 86) and November 30, 2020 (Dkt. 87); and
(2) the Motion’s reference to, and discussion of, Confidential Information, including financial
documents and other materials produced in discovery and governed by paragraph 15 of the
Protective Order (Dkt. 36).
Please contact us with any questions. Your consideration is greatly appreciated.
Respectfully submitted,
/s/ Christian R. Everdell
Mark S. Cohen
Christian R. Everdell
COHEN & GRESSER LLP
800 Third Avenue, 21st Floor
New York, New York 10022
(212) 957-7600
Mark S. Cohen
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-00001972
Discussion 0
No comments yet
Be the first to share your thoughts on this epstein document