Document 8

Case 1:19-cr-00490-RMB Document 8 Filed 07/11/19 Page 1 of 2 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 11, 2019 VIA ECF The Honorable Richard M. Berman United States District Court Southern District of New York United States Courthouse 500 Pearl Street New York, New York 10007 Re: United States v. Jeffrey Epstein, 19 Cr. 490 (RMB) Dear Judge Berman: The Government respectfully submits this letter in response to the defendant's motion for leave to file a supplemental financial disclosure under seal (the "Sealing Motion") in connection with his motion for pretrial release (the "Bail Motion"). The Government takes no position on the defendant's application, but notes that as of this filing the Government still has not yet received any financial disclosure or information from the defense in connection with the defendant's application for bail. It is now more than three days following the defendant's initial presentment, more than seven hours after the defendant's deadline to file his Motion, and less than 24 hours before the Government's deadline to reply. There is no reason that the defendant need have waited until this evening to submit his Sealing Motion, and the Government cannot meaningfully respond to a Bail Motion that contains no material financial information, either under seal or otherwise. Accordingly, the Government respectfully requests that its deadline to respond to the defendant's Bail Motion be extended to at least 24 hours following the defendant's disclosure of any financial information upon which he intends to rely in connection with the Motion. Should DOJ-OGR-00000323 --- PAGE BREAK --- Case 1:20-cr-00330-AJN Document 8 Filed 07/06/20 Page 1 of 2 COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 +1 212 957 7600 phone www.cohengresser.com Mark S. Cohen +1 (212) 957-7600 mcohen@cohengresser.com Christian R. Everdell +1 (212) 957-7600 ceverdell@cohengresser.com July 6, 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: On behalf of our client, Ghislaine Maxwell, we respectfully submit this letter in response to the Court's order from earlier today regarding the scheduling of the arraignment, initial appearance, and bail hearing in this matter. We have been attempting to contact our client at the Metropolitan Detention Center; we were able to speak to her for the first time today just before 9:00pm this evening. She has agreed to waive her physical presence for these proceedings. As directed by the Court, we have met and conferred with the Government regarding scheduling. All parties will be able to proceed remotely on the morning of July 14, 2020. The defense will not be able to proceed on July 9, 2020. We will meet and confer further with the Government tomorrow regarding a proposed briefing schedule and anticipate providing a joint proposed briefing schedule for the Court's consideration by the end of the day. Respectfully submitted, /s/ Mark S. Cohen Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue, 21st Floor DOJ-OGR-00001536 --- PAGE BREAK --- Case 20-3061, Document 8, 09/10/2020, 2927915, Page1 of 1 NOTICE OF APPEARANCE FOR SUBSTITUTE, ADDITIONAL, OR AMICUS COUNSEL Short Title: United States of America v. Ghislaine Maxwell Docket No.: No. 20-3061 Substitute, Additional, or Amicus Counsel's Contact Information is as follows: Name: Adam Mueller Firm: Haddon, Morgan & Foreman, P.C. Address: 150 E. 10th Ave., Denver, CO 80203 Telephone: 303-831-7364 Fax: 303-832-2628 E-mail: amueller@hmflaw.com Appearance for: Defendant-Appellant Ghislaine Maxwell Select One: Substitute counsel (replacing lead counsel: _____________________ ) (name/firm) Substitute counsel (replacing other counsel: _____________________ ) (name/firm) Additional counsel (co-counsel with: Laura A. Menninger/Haddon, Morgan & Foreman, P.C. ) (name/firm) Amicus (in support of: _____________________ ) (party/designation) CERTIFICATION I certify that: I am admitted to practice in this Court and, if required by Interim Local Rule 46.1(a)(2), have renewed my admission on _____________________ OR I applied for admission on _____________________ . Signature of Counsel: s/ Adam Mueller Type or Print Name: Adam Mueller DOJ-OGR-00019278 --- PAGE BREAK --- Case 1:19-cr-00490-RMB Document 8 Filed 07/11/19 Page 2 of 2 Honorable Richard M. Berman United States District Judge July 11, 2019 Page 2 that require adjourning the bail hearing, the Government respectfully requests that the hearing be moved to a date and time convenient for the Court and sufficient to permit the Court to review the Government's reply. Very truly yours, GEOFFREY S. BERMAN United States Attorney By: Alex Rossmiller / Alison Moe / Maurene Comey Assistant United States Attorney Southern District of New York Tel: (212) 637-2415 / 2225 / 2324 Cc: Martin Weinberg, Esq., and Reid Weingarten, Esq., counsel for defendant DOJ-OGR-00000324 --- PAGE BREAK --- Case 1:20-cr-00330-AJN Document 8 Filed 07/06/20 Page 2 of 2 The Honorable Alison J. Nathan July 6, 2020 Page 2 New York, New York 10022 (212) 957-7600 cc: Alison Moe (by e-mail) Alex Rossmiller (by e-mail) Maurene Comey (by e-mail) DOJ-OGR-00001537