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Document 96

AI Analysis

Summary: The letter, submitted by Ghislaine Maxwell's attorneys, includes two versions of her Memorandum in Support of Her Renewed Motion for Bail: a sealed unredacted original and a publicly-filed version with proposed redactions based on privacy concerns and confidential information governed by a Protective Order.
Significance: This document is significant as it reveals the defense's strategy for Ghislaine Maxwell's bail motion and the handling of confidential information in the case.
Key Topics: Ghislaine Maxwell's Renewed Motion for Bail Proposed redactions for public filing Confidential Information and Protective Order
Key People:
  • Ghislaine Maxwell - Defendant
  • Christian R. Everdell - Defense Attorney
  • Mark S. Cohen - Defense Attorney
  • Alison J. Nathan - United States District Judge
Document Type
Letter
Date
12/14/20
Pages
3
Folder
IMAGES001, IMAGES007

Full Text

Case 1:20-cr-00330-AJN Document 96 Filed 12/14/20 Page 1 of 1 COHEN & GRESSER LLP Mark S. Cohen Christian R. Everdell +1 (212) 957-7600 mcohen@cohengresser.com ceverdell@cohengresser.com December 8, 2020 TO BE FILED UNDER SEAL VIA EMAIL (SUBMITTED PURSUANT TO SECTION 2(B) OF JUDGE NATHAN'S INDIVIDUAL PRACTICES IN CRIMINAL CASES) 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, and pursuant to the Court's order (Dkt. 89), we respectfully submit under seal two versions of the Memorandum of Ghislaine Maxwell in Support of Her Renewed Motion for Bail (the "Motion") and accompanying exhibits: an unredacted original to be kept under seal and a version for public filing with proposed narrowly tailored redactions. The proposed redactions are based on the following: (1) privacy concerns, as articulated in our letters of November 25, 2020 (Dkt. 86) and November 30, 2020 (Dkt. 87); and (2) the Motion's reference to, and discussion of, Confidential Information, including financial documents and other materials produced in discovery and governed by paragraph 15 of the Protective Order (Dkt. 36). Please contact us with any questions. Your consideration is greatly appreciated. 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-00001972 --- PAGE BREAK --- Case 20-3061, Document 96, 10/08/2020, 2948491, 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. Maxwell Docket No.: 20-3061 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: Adam Mueller (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: 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: Adam Mueller Date: 10/08/2020 Signature: s/ Adam Mueller (Revised December 2011) DOJ-OGR-00019675 --- PAGE BREAK --- Case 21-58, Document 96, 06/02/2021, 3112207, Page1 of 1 UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT At a Stated Term Of the United States Court of Appeals for the Second Circuit, held at the Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the 2nd day of June, two thousand twenty-one. Before: Pierre N. Leval, Raymond J. Lohier, Jr., Richard J. Sullivan, Circuit Judges. United States of America, Appellee, ORDER Docket Nos. 21-58(L), 21-770(Con) v. Ghislaine Maxwell, AKA Sealed Defendant 1, Defendant - Appellant. Appellant renews her request for pretrial release. In the alternative, she requests that the Court remand this matter to the district court to conduct an evidentiary hearing on the conditions of her confinement. The Government opposes the motion. IT IS HEREBY ORDERED that the motion is DENIED. For the Court: Catherine O'Hagan Wolfe, Clerk of Court Catherine O'Hagan Wolfe DOJ-OGR-00020383

Individual Pages

Page 1 - DOJ-OGR-00001972
Case 1:20-cr-00330-AJN Document 96 Filed 12/14/20 Page 1 of 1 COHEN & GRESSER LLP Mark S. Cohen Christian R. Everdell +1 (212) 957-7600 mcohen@cohengresser.com ceverdell@cohengresser.com December 8, 2020 TO BE FILED UNDER SEAL VIA EMAIL (SUBMITTED PURSUANT TO SECTION 2(B) OF JUDGE NATHAN'S INDIVIDUAL PRACTICES IN CRIMINAL CASES) 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, and pursuant to the Court's order (Dkt. 89), we respectfully submit under seal two versions of the Memorandum of Ghislaine Maxwell in Support of Her Renewed Motion for Bail (the "Motion") and accompanying exhibits: an unredacted original to be kept under seal and a version for public filing with proposed narrowly tailored redactions. The proposed redactions are based on the following: (1) privacy concerns, as articulated in our letters of November 25, 2020 (Dkt. 86) and November 30, 2020 (Dkt. 87); and (2) the Motion's reference to, and discussion of, Confidential Information, including financial documents and other materials produced in discovery and governed by paragraph 15 of the Protective Order (Dkt. 36). Please contact us with any questions. Your consideration is greatly appreciated. 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-00001972
Page 1 - DOJ-OGR-00019675
Case 20-3061, Document 96, 10/08/2020, 2948491, 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. Maxwell Docket No.: 20-3061 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: Adam Mueller (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: 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: Adam Mueller Date: 10/08/2020 Signature: s/ Adam Mueller (Revised December 2011) DOJ-OGR-00019675
Page 1 - DOJ-OGR-00020383
Case 21-58, Document 96, 06/02/2021, 3112207, Page1 of 1 UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT At a Stated Term Of the United States Court of Appeals for the Second Circuit, held at the Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the 2nd day of June, two thousand twenty-one. Before: Pierre N. Leval, Raymond J. Lohier, Jr., Richard J. Sullivan, Circuit Judges. United States of America, Appellee, ORDER Docket Nos. 21-58(L), 21-770(Con) v. Ghislaine Maxwell, AKA Sealed Defendant 1, Defendant - Appellant. Appellant renews her request for pretrial release. In the alternative, she requests that the Court remand this matter to the district court to conduct an evidentiary hearing on the conditions of her confinement. The Government opposes the motion. IT IS HEREBY ORDERED that the motion is DENIED. For the Court: Catherine O'Hagan Wolfe, Clerk of Court Catherine O'Hagan Wolfe DOJ-OGR-00020383