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efta-efta00019029DOJ Data Set 8Correspondence

EFTA00019029

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DOJ Data Set 8
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efta-efta00019029
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EFTA Disclosure
Text extracted via OCR from the original document. May contain errors from the scanning process.
From: To: Cc: Subject: RE: Meet and Confer Date: Mon, 22 Mar 2021 19:01:58 +0000 Attachments: Exhibit 1 I (Proposed Redactions Per Order).pdf; _ _ - - 2021.02.26_Govemment_Omnibus_Opposition_to_Maxwell_Defense_Motions_FINALJPr oposed_Redactions_Per_Order).pdf Inline-Images: image001.jpg; image002.jpg Thanks for your email. In accordance with Judge Nathan's order, we are writing to confer regarding Exhibit 11 and your cover letter dated March 9, 2021. Attached please find proposed redactions to Exhibit 11. We do not believe any redactions are necessary to your cover letter. We intend to the file the brief with the redactions as set forth in Judge Nathan's March 18, 2021 order, attached here for your convenience. We note that the redactions contained on pages 118 to 119 redact quotations from and references to a document that you filed under seal (Exhibit H). We understand that the quoted portions of that document are also under seal on the civil docket before Judge Preska. Given those facts, we wanted to double check with you to see whether you in fact want those redactions removed. We will defer to you on whether these should be redacted. Best, From: Christian Everdell <[email protected]> Sent: Monday, March 22, 2021 2:29 PM Subject: Meet and Confer Per Judge Nathan's order, we need to meet and confer today about proposed redactions to Exhibit 11 of your opposition and to our letter dated March 9, 2021 regarding redactions. We are free from now through the rest of the afternoon. Please let us know what works for you. Regards, Chris Christian R Everdell EFTA00019029 COHEN & GRESSER LLP Paris I Washington DC I London CONFIDENTIALITY NOTICE: The information contained in this e-mail may be confidential and/or privileged. This e-mail is intended to be reviewed initially by only the individual named above. If the reader of this e-mail is not the intended recipient or a representative of the intended recipient. you are hereby notified that any review. dissemination or copying of this e-mail or the information contained herein is prohibited. If you have received this e-mail in error. please immediately notify the sender by telephone and permanently delete this e-mail. Thank you. PRIVACY: A complete copy of our privacy policy can be viewed al Mos://v.ww.cohenuressercom/privacv-PolicX EFTA00019030

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Related Documents (6)

DOJ Data Set 8CorrespondenceUnknown

EFTA00019897

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Court UnsealedLegal FilingUnknown

Court Filing: 133

Ghislaine Maxwell's defense team files a motion to suppress evidence obtained from a government subpoena and to dismiss Counts Five and Six of the indictment, citing the Due Process Clause. The motion is supported by a memorandum of law and exhibits. The defense attorneys representing Maxwell are listed, along with their contact information.

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House OversightLegal FilingUnknown

Defense attorney Christian R. Everdell requests that the court order the MDC to accept two hard driv...

Defense attorney Christian R. Everdell requests that the court order the MDC to accept two hard drives containing non-Highly Confidential discovery materials for Ghislaine Maxwell's use. The hard drives are organized in a user-friendly format, and the government does not object to the request. The MDC Legal Department has expressed concerns and is given the opportunity to note objections.

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Court UnsealedLegal FilingUnknown

Declaration in Support of Motion to Withdraw as Co-Counsel: 798-1

Christian R. Everdell of Cohen & Gresser LLP declares that the firm is withdrawing as co-counsel for Ghislaine Maxwell with her consent, as Markus Moss PLLC has taken over her representation for the government's motion to unseal grand jury transcripts. Cohen & Gresser LLP represented Maxwell during her trial and sentencing but not in her appellate proceedings. The firm will share its files with Markus Moss PLLC upon request.

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Court UnsealedCorrespondenceUnknown

Court Filing - Letter to Judge: Case1:20-cr-03320-AJN Document 292 Filed 08/27/20 Page 20 of 1164

The defense attorneys for Ghislaine Maxwell request a protective order from Judge Alison J. Nathan to govern the handling of discovery materials. The parties have reached agreement on most provisions but remain at odds over restrictions on government witnesses and the disclosure of alleged victim identities.

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Court UnsealedLegal FilingUnknown

Court filings: 8

The documents include court filings related to the cases of Ghislaine Maxwell and Jeffrey Epstein. The first filing concerns the scheduling of Maxwell's arraignment and bail hearing, while the second is related to Epstein's bail motion and financial disclosure.

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