DOJ-OGR-00002759.jpg

688 KB

Extraction Summary

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

Document Information

Type: Legal correspondence / court filing cover letter
File Size: 688 KB
Summary

A legal cover letter dated March 15, 2021, from attorneys Cohen and Everdell of Cohen & Gresser LLP to Judge Alison J. Nathan. The letter lists ten reply memoranda being filed on behalf of their client, Ghislaine Maxwell, in the case United States v. Ghislaine Maxwell. These filings relate to motions to dismiss indictments, suppress evidence (involving a redacted subpoena target), sever counts, and request a bill of particulars.

People (4)

Name Role Context
Mark S. Cohen Attorney
Partner at Cohen & Gresser LLP representing Ghislaine Maxwell
Christian R. Everdell Attorney
Partner at Cohen & Gresser LLP representing Ghislaine Maxwell
Alison J. Nathan Judge
The Honorable Judge, United States District Court, Southern District of New York
Ghislaine Maxwell Defendant
Client of Cohen & Gresser LLP, subject of the indictment

Organizations (3)

Name Type Context
Cohen & Gresser LLP
Law firm representing the defendant
United States District Court Southern District of New York
Court jurisdiction handling the case
Department of Justice (DOJ)
Implied by the footer stamp DOJ-OGR

Timeline (1 events)

March 15, 2021
Filing of ten reply memoranda in the case United States v. Ghislaine Maxwell
United States District Court, Southern District of New York

Locations (2)

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

Relationships (2)

Mark S. Cohen Attorney-Client Ghislaine Maxwell
Letter states 'On behalf of our client, Ghislaine Maxwell'
Christian R. Everdell Attorney-Client Ghislaine Maxwell
Listed as attorney on letterhead for the firm representing Maxwell

Key Quotes (3)

"On behalf of our client, Ghislaine Maxwell, we will be filing the following reply memoranda with accompanying exhibits"
Source
DOJ-OGR-00002759.jpg
Quote #1
"Reply Memorandum in Support of Motion to Dismiss the Superseding Indictment for Breach of the Non-Prosecution Agreement"
Source
DOJ-OGR-00002759.jpg
Quote #2
"Reply Memorandum in Support of Motion Under the Due Process Clause to Suppress All Evidence Obtained from the Government’s Subpoena to [REDACTED]"
Source
DOJ-OGR-00002759.jpg
Quote #3

Full Extracted Text

Complete text extracted from the document (1,963 characters)

Case 1:20-cr-00330-AJN Document 166 Filed 03/15/21 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
March 15, 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 reply memoranda with accompanying exhibits:
1. Reply Memorandum in Support of Motion to Dismiss the Superseding Indictment for Breach of the Non-Prosecution Agreement
2. Reply Memorandum in Support of Motion to Dismiss Counts One through Four of the Superseding Indictment as Time-Barred
3. Reply Memorandum in Support of 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. Reply Memorandum in Support of Motion to Dismiss Counts Five and Six of the Superseding Indictment Because the Alleged Misstatements Are Not Perjurious as a Matter of Law
5. Reply Memorandum in Support of Motion for a Severance of and Separate Trial on Counts Five and Six of the Superseding Indictment
6. Reply Memorandum in Support of Motion to Strike Surplusage from the Superseding Indictment
7. Reply Memorandum in Support of Motion to Dismiss Counts One Through Six of the Superseding Indictment for Pre-Indictment Delay
8. Reply Memorandum in Support of Motion to Dismiss Either Count One or Count Three of the Superseding Indictment as Multiplicitous
9. Reply Memorandum in Support of Motion to Dismiss the Superseding Indictment as It Was Obtained in Violation of the Sixth Amendment
10. Reply Memorandum in Support of Motion for a Bill of Particulars and Pretrial Disclosures
DOJ-OGR-00002759

Discussion 0

Sign in to join the discussion

No comments yet

Be the first to share your thoughts on this epstein document