DOJ-OGR-00002275(1).jpg

665 KB

Extraction Summary

4
People
3
Organizations
2
Locations
1
Events
2
Relationships
3
Quotes

Document Information

Type: Legal correspondence / court filing
File Size: 665 KB
Summary

A legal letter dated January 25, 2021, from the law firm Cohen & Gresser LLP to Judge Alison J. Nathan regarding the case United States v. Ghislaine Maxwell. The letter lists 12 specific pretrial motions being filed by the defense, including motions to dismiss various counts of the indictment, suppress evidence, and separate trials. Two of the motions (items 3 and 11) contain redactions regarding the target of a government subpoena.

People (4)

Name Role Context
Ghislaine Maxwell Defendant / Client
Subject of the criminal case and client of Cohen & Gresser LLP.
Alison J. Nathan Judge
Recipient of the letter; Judge for the Southern District of New York.
Mark S. Cohen Attorney
Defense attorney for Ghislaine Maxwell; Sender of the letter.
Christian R. Everdell Attorney
Defense attorney for Ghislaine Maxwell; Listed on letterhead.

Organizations (3)

Name Type Context
Cohen & Gresser LLP
Law firm representing Ghislaine Maxwell.
United States District Court, Southern District of New York
Court where the case is being heard.
DOJ
Department of Justice (implied by footer DOJ-OGR-00002275).

Timeline (1 events)

2021-01-25
Filing of pretrial motions in United States v. Ghislaine Maxwell.
Southern District of New York
Ghislaine Maxwell Cohen & Gresser LLP Judge Alison J. Nathan

Locations (2)

Location Context
Address of Cohen & Gresser LLP.
Address of the United States District Court.

Relationships (2)

Ghislaine Maxwell Client/Attorney Cohen & Gresser LLP
Letter states 'On behalf of our client, Ghislaine Maxwell'
Alison J. Nathan Judge/Defendant Ghislaine Maxwell
Letter addressed to Judge Nathan regarding US v. Ghislaine Maxwell

Key Quotes (3)

"On behalf of our client, Ghislaine Maxwell, we will be filing the following pretrial motions with accompanying exhibits"
Source
DOJ-OGR-00002275(1).jpg
Quote #1
"Motion to Dismiss the Superseding Indictment for Breach of the Non-Prosecution Agreement"
Source
DOJ-OGR-00002275(1).jpg
Quote #2
"Motion Under the Due Process Clause to Suppress All Evidence Obtained from the Government’s Subpoena to [REDACTED] and to Dismiss Counts Five and Six"
Source
DOJ-OGR-00002275(1).jpg
Quote #3

Full Extracted Text

Complete text extracted from the document (1,945 characters)

Case 1:20-cr-00330-AJN Document 118 Filed 01/25/21 Page 1 of 2
C&G 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
January 25, 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 the following pretrial motions with accompanying exhibits:
1. Motion to Dismiss the Superseding Indictment for Breach of the Non-Prosecution Agreement
2. Motion to Dismiss Counts One through Four of the Superseding Indictment as Time-Barred
3. Motion Under the Due Process Clause to Suppress All Evidence Obtained from the Government’s Subpoena to [REDACTED] and to Dismiss Counts Five and Six
4. Motion to Dismiss Counts Five and Six of the Superseding Indictment Because the Alleged Misstatements Are Not Perjurious as a Matter of Law
5. Motion for a Severance of and Separate Trial on Counts Five and Six of the Superseding Indictment
6. Motion to Strike Surplusage from the Superseding Indictment
7. Motion to Dismiss Counts One Through Six of the Superseding Indictment for Pre-Indictment Delay
8. Motion to Dismiss Either Count One or Count Three of the Superseding Indictment as Multiplicitous
9. Motion to Dismiss the Superseding Indictment as It Was Obtained in Violation of the Sixth Amendment
10. Motion for a Bill of Particulars and Pretrial Disclosures
11. Motion Under the Fourth Amendment, Martindell, and the Fifth Amendment to Suppress All Evidence Obtained from the Government’s Subpoena to [REDACTED] and to Dismiss Counts Five and Six
12. Motion to Dismiss Counts One through Four of the Superseding Indictment for Lack of Specificity
DOJ-OGR-00002275

Discussion 0

Sign in to join the discussion

No comments yet

Be the first to share your thoughts on this epstein document