Document 85

Case 1:20-cr-00330-AJN Document 85 Filed 12/04/20 Page 1 of 2 COHEN & GRESSER LLP Mark S. Cohen Christian R. Everdell +1 (212) 957-7600 mcohen@cohengresser.com ceverdell@cohengresser.com 800 Third Avenue New York, NY 10022 +1 212 957 7600 phone www.cohengresser.com December 4, 2020 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: Per the Court's order (Dkt. 81), the parties have conferred regarding the briefing schedule for Ghislaine Maxwell's renewed motion for release on bail. The defense respectfully requests that the hearing take place before the holidays and the government is amenable to that schedule. Accordingly, the parties propose the following briefing schedule: Defense submission: December 7, 2020 Government response: December 16, 2020 Defense reply due: December 18, 2020 Hearing: December 21, 2020 (subject to the Court's availability) Per the Court's order, the defense will send our submissions to the Court under seal on the dates mentioned above and will include a proposed redacted version of the submission to be filed on the docket for the Court's consideration. We ask that the Court order the government to follow the same procedure for its submission. Also, although the Court's Individual Practices in Criminal Cases do not contain a page limit for motions, we are mindful of the Court's 25-page limit for civil motions. In light of the numerous topics the defense must cover in connection with the renewed bail application, the defense respectfully requests leave to file a motion not to exceed 40 pages. The defense does not object to the government receiving a similar enlargement of pages to respond. Your consideration is greatly appreciated. DOJ-OGR-00001849 --- PAGE BREAK --- Case 21-58, Document 85, 04/27/2021, 3087699, Page1 of 1 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 27, 2021 Docket #: 21-58cr 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 CASE MANAGER CHANGE The case manager assigned to this matter has been changed. Inquiries regarding this case may be directed to 212-857-8513. DOJ-OGR-00020322 --- PAGE BREAK --- Case 22-1426, Document 85, 07/13/2023, 3540976, Page1 of 1 UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT ORAL ARGUMENT STATEMENT (Local Rule 34.1(a)) TO REQUEST ORAL ARGUMENT, FILL OUT THIS FORM AND FILE IT WITH THE CLERK WITHIN 14 DAYS AFTER THE FILING OF THE LAST APPELLEE BRIEF. IF THIS FORM IS NOT TIMELY FILED, YOU WILL NOT BE PERMITTED TO ARGUE IN PERSON. Short Title of Case: United States v. Ghislaine Maxwell Docket No.: 22-1426 Name of Party: Ghislaine Maxwell Status of Party (e.g., appellant, cross-appellee, etc.): Appellant Check one of the three options below: I want oral argument. I want oral argument only if at least one other party does. I do not want oral argument. An attorney whose preference depends on whether other attorneys will argue should consider conferring before requesting argument. After the appeal has been scheduled for oral argument, a motion by counsel to forgo oral argument, even on consent, may be denied. If no party wants oral argument, the case will be decided on the basis of the written briefs. If you want oral argument, you must appear in Court on the date set by the Court for oral argument. The Court may determine to decide a case without oral argument even if the parties request it. If you want oral argument, state the name of the person who will argue: Name: Diana Fabi Samson (An attorney must be admitted to practice before the Court in accordance with Local Rule 46.1.) If you want oral argument, list any dates (including religious holidays), that fall in the interval from 6 to 20 weeks after the due date of this form, that the person who will argue is not available to appear in Court: September 6, 2023; September 7, 2023; September 18, 2023; September 25, 2023 ANYONE WHO WANTS TO ARGUE MUST UPDATE THE COURT IN WRITING OF ANY CHANGE IN AVAILABILITY. THE COURT MAY CONSIDER A FAILURE TO UPDATE ABOUT AVAILABILITY WHEN DECIDING A MOTION TO POSTPONE A SET ARGUMENT DATE. Filed by: Print Name: Diana Fabi Samson Date: 7/13/2023 Signature: /s/Diana Fabi Samson (Revised December 2011) DOJ-OGR-00021742 --- PAGE BREAK --- Case 1:20-cr-00330-AJN Document 85 Filed 12/04/20 Page 2 of 2 The Honorable Alison J. Nathan December 4, 2020 Page 2 Respectfully submitted, /s/ Christian R. Everdell Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue, 21st Floor New York, New York 10022 (212) 957-7600 cc: All counsel of record (via email) DOJ-OGR-00001850