Document 31

Case 1:19-cr-00490-RMB Document 31 Filed 07/18/19 Page 1 of 1 LAW OFFICE OF MARC FERNICH MARC FERNICH maf@fernichlaw.com ALSO ADMITTED IN MASSACHUSETTS 810 SEVENTH AVENUE, SUITE 620 NEW YORK, NEW YORK 10019 212-446-2346 FAX: 212-459-2299 www.fernichlaw.com July 18, 2019 BY ECF Hon. Richard M. Berman USDJ-SDNY Daniel P. Moynihan US Courthouse 500 Pearl St. Courtroom 17B New York, NY 10007-1312 Re: US v. Jeffrey Epstein, 19 CR 490 (SDNY) (RMB) Dear Judge Berman: Jeffrey Epstein replies to yesterday's government letter. Epstein was given the passport at issue by a friend. Some Jewish-Americans were informally advised at the time to carry identification bearing a non-Jewish name when traveling internationally in case of hijacking. He never used the document to travel internationally and never presented it to any immigration or customs authority. The passport stamps, predating his receipt of the document, do not reflect Mr. Epstein's entries or exits. His expired US passports, seized by the government and in its possession, would verify his true travel. The defense has asked the government to bring the original document to court for examination and inspection. As Mr. Epstein truthfully reported in his Pretrial Services interview, he is a life-long American citizen. He has no other citizenship or legal permanent residency. Respectfully, Marc Fernich Martin Weinberg Reid Weingarten cc: All counsel DOJ-OGR-00000471 --- PAGE BREAK --- Case 21-770, Document 31, 04/05/2021, 3070287, Page1 of 2 United States Court of Appeals for the Second Circuit Thurgood Marshall U.S. Courthouse 40 Foley Square New York, NY 10007 DEBRA ANN LIVINGSTON CHIEF JUDGE CATHERINE O'HAGAN WOLFE CLERK OF COURT Date: April 05, 2021 Docket #: 21-58 DC Docket #: 1:20-cr-330-1 DC Court: SDNY (NEW YORK CITY) DC Docket #: 1:20-cr-330-1 DC Court: SDNY (NEW YORK CITY) DC Judge: Nathan Short Title: United States of America v. Maxwell NOTICE OF DEFECTIVE FILING On April 05, 2021 the Notice of Appearance as Additional Counsel, on behalf of the Appellee United States of America, was submitted in the above referenced case. The document does not comply with the FRAP or the Court's Local Rules for the following reason(s): Failure to submit acknowledgment and notice of appearance (Local Rule 12.3) Failure to file the Record on Appeal (FRAP 10, FRAP 11) Missing motion information statement (T-1080 - Local Rule 27.1) Missing supporting papers for motion (e.g., affidavit/affirmation/declaration) (FRAP 27) Insufficient number of copies (Local Rules: 21.1, 27.1, 30.1, 31.1) Improper proof of service (FRAP 25) Missing proof of service Served to an incorrect address Incomplete service (Anders v. California 386 U.S. 738 (1967)) Failure to submit document in digital format (Local Rule 25.1) Not Text-Searchable (Local Rule 25.1, Local Rules 25.2), click here for instructions on how to make PDFs text searchable Failure to file appendix on CD-ROM (Local Rule 25.1, Local Rules 25.2) Failure to file special appendix (Local Rule 32.1) Defective cover (FRAP 32) Incorrect caption (FRAP 32) Wrong color cover (FRAP 32) Docket number font too small (Local Rule 32.1) Incorrect pagination, click here for instructions on how to paginate PDFs (Local Rule 32.1) Incorrect font (FRAP 32) DOJ-OGR-00001310 --- PAGE BREAK --- Case 1:20-cr-00330-AJN Document 31 Filed 07/27/20 Page 1 of 1 U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 July 27, 2020 VIA ECF The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully submits this letter to request the opportunity to respond to defense counsel's letter motion seeking the entry of a protective order, which was filed this morning. The Government and defense counsel were in discussions - as recently as 6 p.m. last night - in the hopes of jointly proposing a protective order. Until seeing the filing on ECF this morning, the Government had understood those discussions to be ongoing. In light of the defense's letter, however, the Government respectfully requests until 5 p.m. tomorrow to submit a response. Respectfully submitted, AUDREY STRAUSS Acting United States Attorney By: /s/ Alex Rossmiller / Alison Moe / Maurene Comey Assistant United States Attorneys Southern District of New York Tel: (212) 637-2324 Cc: All counsel of record (by ECF) DOJ-OGR-00001662 --- PAGE BREAK --- Case 20-3061, Document 31, 09/15/2020, 2931599, Page1 of 1 Haddon, Morgan and Foreman, P.C Adam Mueller 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 FX 303.832.2628 www.hmflaw.com amueller@hmflaw.com September 15, 2020 Gerard Whidbee United States Court of Appeals for the Second Circuit United States Courthouse 40 Foley Square New York, NY 10008 Re: United States v. Maxwell, No. 20-3061 (2d Cir.) Dear Mr. Whidbee: Under Local Rule 31.2(a)(1)(A), Ms. Maxwell selects October 22, 2020, as the due date for her opening brief, which is 42 days from the filing of Form B, which indicates that no transcript will be required or ordered for this appeal. Sincerely, Adam Mueller Counsel for Defendant-Appellant Ghislaine Maxwell CC: All counsel of record, via ECF DOJ-OGR-00019340 --- PAGE BREAK --- Case 21-770, Document 31, 04/05/2021, 30702877, Page2 of 2 Oversized filing (FRAP 27 (motion), FRAP 32 (brief)) Missing Amicus Curiae filing or motion (Local Rule 29.1) Untimely filing Incorrect Filing Event X Other: IF COUNSEL WISHES TO BE ADDED TO BOTH CASES, YOU MUST LIST BOTH DOCKET NUMBERS ON THE FORM 21-58 - L AND 21-770 CON. Please cure the defect and resubmit the document, with the required copies if necessary, no later than April 07, 2021. The resubmitted documents, if compliant with FRAP and the Local Rules, will be deemed timely filed. Failure to cure the defect by the date set forth above will result in the document being stricken. An appellant's failure to cure a defective filing may result in the dismissal of the appeal. Inquiries regarding this case may be directed to 212-857-8577. DOJ-OGR-00001311