DOJ-OGR-00005377.jpg
634 KB
Extraction Summary
3
People
4
Organizations
2
Locations
3
Events
2
Relationships
4
Quotes
Document Information
Type:
Legal correspondence (letter motion)
File Size:
634 KB
Summary
This document is a letter motion filed on October 25, 2021, by defense attorney Christian R. Everdell to Judge Alison J. Nathan in the case of United States v. Ghislaine Maxwell. The defense requests a one-week extension (to November 3, 2021) to file the joint proposed jury charge and verdict sheet, citing conflicting deadlines including Rule 412 briefing. The government has consented to this extension request.
People (3)
| Name | Role | Context |
|---|---|---|
| Christian R. Everdell | Defense Attorney |
Author of the letter, representing the defense (Ghislaine Maxwell).
|
| Alison J. Nathan | Judge |
Recipient of the letter, presiding Judge of the United States District Court.
|
| Ghislaine Maxwell | Defendant |
Named in the case caption: United States v. Ghislaine Maxwell.
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| Cohen & Gresser LLP |
Firm representing the defense.
|
|
| United States District Court, Southern District of New York |
Jurisdiction where the case is being heard.
|
|
| The Government |
Referring to the US Attorney's Office/prosecutors involved in the case.
|
|
| DOJ |
Department of Justice, indicated in the footer stamp.
|
Timeline (3 events)
November 1, 2021
Agreed deadline for defense to send redlined counterproposals to government (by 7:00 p.m.).
N/A
Defense
Government
November 3, 2021
Requested new deadline for filing joint proposed jury charge and verdict sheet.
SDNY
Defense
Government
October 27, 2021
Original deadline for joint proposed jury charge and verdict sheet.
SDNY
Defense
Government
Locations (2)
| Location | Context |
|---|---|
|
Address of the Court.
|
|
|
Address of Cohen & Gresser LLP.
|
Relationships (2)
Everdell writes on behalf of the defense in U.S. v. Maxwell.
Everdell notes he has 'met and conferred' with the government.
Key Quotes (4)
"We respectfully submit this letter to request a one-week extension until November 3, 2021, to file the joint proposed jury charge and verdict sheet"Source
DOJ-OGR-00005377.jpg
Quote #1
"The government consents to this request."Source
DOJ-OGR-00005377.jpg
Quote #2
"Because of the press of other deadlines in this case—including the motions in limine responses and replies, and the Rule 412 briefing"Source
DOJ-OGR-00005377.jpg
Quote #3
"The parties will submit the final joint proposed request to charge and verdict sheet, with the areas of continued disagreement shown in redline"Source
DOJ-OGR-00005377.jpg
Quote #4
Full Extracted Text
Complete text extracted from the document (1,818 characters)
Case 1:20-cr-00330-PAE Document 369 Filed 10/25/21 Page 1 of 1
C&G
COHEN & GRESSER LLP
800 Third Avenue
New York, NY 10022
+1 212 957 7600 phone
www.cohengresser.com
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
+1 (212) 957-7600
ceverdell@cohengresser.com
October 25, 2021
BY ECF
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
United States Courthouse
40 Foley Square
New York, NY 10007
United States District Court
Southern District of New York
United States Courthouse
40 Foley Square
New York, NY 10007
Re: United States v. Ghislaine Maxwell, S2 20 Cr. 330 (AJN)
Dear Judge Nathan:
We respectfully submit this letter to request a one-week extension until November 3, 2021, to file the joint proposed jury charge and verdict sheet, which are currently due on October 27, 2021. See 8/27/2021 Order (Dkt. 330). The government consents to this request.
On October 20, 2021, the government provided the defense with its proposed jury charge. Because of the press of other deadlines in this case—including the motions in limine responses and replies, and the Rule 412 briefing—the defense requests an additional week to provide its counterproposals to the government and to submit the final proposed jury charge to the Court.
The government and the defense have met and conferred and agreed that the defense will send the government a redlined version of the government’s proposed jury charge containing the defense’s counterproposals by 7:00 p.m. on November 1, 2021. The parties will submit the final joint proposed request to charge and verdict sheet, with the areas of continued disagreement shown in redline, on November 3, 2021. We respectfully request that the Court approve this revised schedule.
Sincerely,
/s/ Christian Everdell
Christian R. Everdell
COHEN & GRESSER LLP
800 Third Avenue, 21st Floor
New York, New York 10022
(212) 957-7600
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)
DOJ-OGR-00005377
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