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COHEN & GRESSER LLP

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Unknown
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EFTA 00084344
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2
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3
Integrity
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Summary

COHEN & GRESSER LLP Christian R. I VIA ECF. The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse July 6, 2020 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. Pursuant to the Court's order, we have attempted to contact our client at the Metropolitan Detention Center, but we have been unable to speak to her at this point. We will continue trying to contact her to discuss the topics raised in the Court's order. We anticipate that our client will be amenable to proceeding remotely, subject to us having the opportunity to speak to her. As directed by the Court, we have met and conferred with the Government regarding scheduling. Assuming our client agrees to pr

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EFTA Disclosure
Text extracted via OCR from the original document. May contain errors from the scanning process.
COHEN & GRESSER LLP Christian R. I VIA ECF. The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse July 6, 2020 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. Pursuant to the Court's order, we have attempted to contact our client at the Metropolitan Detention Center, but we have been unable to speak to her at this point. We will continue trying to contact her to discuss the topics raised in the Court's order. We anticipate that our client will be amenable to proceeding remotely, subject to us having the opportunity to speak to her. As directed by the Court, we have met and conferred with the Government regarding scheduling. Assuming our client agrees to proceed remotely, 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. EFTA00084344 The Honorable Alison J. Nathan July 6, 2020 Page 2 Once we have spoken to our client, we will meet and confer further with the Government regarding a proposed briefing schedule. Assuming we are able to speak to our client tomorrow, we anticipate providing a joint proposed briefing schedule for the Court's consideration by the end of the day. Respectfully submitted, Is/ Mark S. Cohen Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP IMm cc: e-mail) (by e-mail) (by e-mail) EFTA00084345

Related Documents (6)

Court UnsealedTestimonyUnknown

Court Transcript: 773

The transcript details a segment of Ghislaine Maxwell's jury trial where the jury requests supplies and a definition for 'enticement'. The prosecution and defense discuss how to respond, with the judge referencing previous cases (United States v. Almonte and United States v. Dupigny) to define 'entice' as 'to attract, induce, or lure using hope or desire'.

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DOJ Data Set 9OtherUnknown

UNITED STATES DISTRICT COURT

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. x 20 Cr. 330 (AJN) MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF HER RENEWED MOTION FOR BAIL Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP New York, NY 10022 Phone: Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Denver, CO 80203 Phone: Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim New York, NY 10011 Phone: Attorneys for Ghislaine Maxwell EFTA00094289 TABLE OF CONTENTS Page PRELIMINARY STATEMENT 1 ARGUMENT 7 I. Reconsideration of the Court's Bail Decision is Appropriate Under 18 U.S.C. § 3142(O 7 II. Ms. Maxwell Should Be Granted Bail Under the Proposed Strict Bail Conditions 10 A. Ms. Maxwell Has Deep Family Ties to the United States and Numerous Sureties to Support Her Bond 10 1. Ms. Maxwell is Devoted to Her Spouse and Stepchildren and Would Never Destroy Her Family By Leaving th

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OtherUnknown

LBUCmaxl

120 LBUCmaxl UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. Before: 20 CR 330 (AJN) Jury Trial New York, N.Y. November 30, 2021 8:50 a.m. HON. ALISON J. NATHAN, APPEARANCES DAMIAN United States Attorney for the Southern District of New York BY: Assistant United States Attorneys HADDON MORGAN AND FOREMAN Attorneys for Defendant BY: JEFFREY S. PAGLIUCA CHRISTIAN R. EVERDELL LAURA A. MENNINGER -and- BOBBI C. STERNHEIM -and- RENATO STABILE Also Present: District Judge , FBI NYPD Sunny Drescher, Paralegal, U.S. Attorney's Office Ann Lundberg, Paralegal, Haddon Morgan and Foreman SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068582 121 LBUCmaxl 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 (Jury not present) THE COURT: Looks like we have everybody. Matt

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Court UnsealedLegal FilingUnknown

Court Filing: 123

Ghislaine Maxwell's defense team filed a motion to dismiss Counts One through Four of the superseding indictment for lack of specificity. The motion was filed on January 25, 2021, in the United States District Court for the Southern District of New York. The defense team is represented by multiple attorneys from different law firms.

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DOJ Data Set 9OtherUnknown

UNITED STATES DISTRICT COURT

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. x 20 Cr. 330 (AJN) MEMORANDUM IN SUPPORT OF GHISLAINE MAXWELL'S THIRD MOTION FOR RELEASE ON BAIL Bobbi C. Sternheim Law Offices of Bobbi C. Sternheim Christian R. Everdell COHEN & GRESSER LLP Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Attorneys for Ghislaine Maxwell EFTA00090990 INTRODUCTION Ghislaine Maxwell respectfully submits this Memorandum in Support of her Third Motion for Release on Bail. As Ms. Maxwell has stated on numerous occasions and reaffirms here: she has no intention or desire to leave this country. She is an American citizen, has lived in United States for 30 years, has strong family ties and the support of friends and family residing in this country. She wants nothing more than to remain in the United States under whatever conditions the Court deems necessary so that she can effectively prepare fo

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Court UnsealedLegal FilingUnknown

Court Filing: 121

Ghislaine Maxwell's defense team filed a motion to dismiss either Count One or Count Three of the superseding indictment, arguing that they are multiplicitous. The motion was filed on January 25, 2021, in the United States District Court for the Southern District of New York. The defense team is represented by multiple attorneys from different law firms.

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