COHEN & GRESSER LLP
Christian R. Everdell
+1 (212) 957-7600
ceverdell@cohengresser.com
800 Third Avenue
New York, NY 10022
+1 212 957 7600 phone
www.cohengresser.com
USDC SDNY
DOCUMENT
ELECTRONICALLY FILED
DOC #:
DATE FILED: 1/5/21
December 31, 2020
BY ECF
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
United States Courthouse
40 Foley Square
New York, NY 10007
Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan:
We write on behalf of our client, Ghislaine Maxwell, to respectfully request a two-week extension of time to file our pretrial motions and to shift the other motion deadlines forward by two weeks. We have conferred with the government, which has consented to the requested extension and the modified briefing schedule. The requested extension is necessary given the large volume of discovery produced by the government, which we are still reviewing, and to ensure that defense counsel can adequately discuss the motions with our client and have her review them. As the Court is aware, Ms. Maxwell was recently placed in quarantine for 14 days and in-person legal visits at MDC have been indefinitely suspended due to COVID, which has constrained our ability to confer with her.
Under the Court's original briefing schedule, the defendant's pretrial motions were due on December 21, 2020, the government's response was due January 22, 2021, and the defendant's reply was due on February 5, 2021. (Dkt. 25). The Court agreed to move those deadlines by three weeks because the government needed additional time to finish producing discovery. (Dkt. 72). Under the current briefing schedule, the defendant's pretrial motions are due on January 11, 2020, the government's response is due February 12, 2021, and the defendant's reply is due on February 19, 2021. (Id.). We respectfully request that the Court so order the briefing schedule below. The next scheduled appearance before the Court is the first day of trial on July 12, 2021.
January 25, 2021 Defendant's pretrial motions due
February 26, 2021 Government's response due
March 5, 2021 Defendant's reply due
SO ORDERED.
1/5/21
ALISON J. NATHAN
United States District Judge
DOJ-OGR-00002257
@epsteinpedia
CA:
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Document 108
AI Analysis
Summary: The defense team for Ghislaine Maxwell requested a two-week extension to file pretrial motions due to the large volume of discovery and COVID-19 related quarantine constraints. The government consented, and the court granted the request, adjusting the briefing schedule accordingly.
Significance: This document is significant as it reveals the challenges faced by Ghislaine Maxwell's defense team due to COVID-19 quarantine and their request for an extension to file pretrial motions, which was granted by the court.
Key Topics:
Ghislaine Maxwell's pretrial motions
Extension of time to file motions
COVID-19 quarantine impact on legal proceedings
Key People:
- Ghislaine Maxwell - Defendant
- Christian R. Everdell - Defense Attorney
- Alison J. Nathan - United States District Judge
Full Text
COHEN & GRESSER LLP
Christian R. Everdell
+1 (212) 957-7600
ceverdell@cohengresser.com
800 Third Avenue
New York, NY 10022
+1 212 957 7600 phone
www.cohengresser.com
USDC SDNY
DOCUMENT
ELECTRONICALLY FILED
DOC #:
DATE FILED: 1/5/21
December 31, 2020
BY ECF
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
United States Courthouse
40 Foley Square
New York, NY 10007
Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan:
We write on behalf of our client, Ghislaine Maxwell, to respectfully request a two-week extension of time to file our pretrial motions and to shift the other motion deadlines forward by two weeks. We have conferred with the government, which has consented to the requested extension and the modified briefing schedule. The requested extension is necessary given the large volume of discovery produced by the government, which we are still reviewing, and to ensure that defense counsel can adequately discuss the motions with our client and have her review them. As the Court is aware, Ms. Maxwell was recently placed in quarantine for 14 days and in-person legal visits at MDC have been indefinitely suspended due to COVID, which has constrained our ability to confer with her.
Under the Court's original briefing schedule, the defendant's pretrial motions were due on December 21, 2020, the government's response was due January 22, 2021, and the defendant's reply was due on February 5, 2021. (Dkt. 25). The Court agreed to move those deadlines by three weeks because the government needed additional time to finish producing discovery. (Dkt. 72). Under the current briefing schedule, the defendant's pretrial motions are due on January 11, 2020, the government's response is due February 12, 2021, and the defendant's reply is due on February 19, 2021. (Id.). We respectfully request that the Court so order the briefing schedule below. The next scheduled appearance before the Court is the first day of trial on July 12, 2021.
January 25, 2021 Defendant's pretrial motions due
February 26, 2021 Government's response due
March 5, 2021 Defendant's reply due
SO ORDERED.
1/5/21
ALISON J. NATHAN
United States District Judge
DOJ-OGR-00002257
--- PAGE BREAK ---
Case 1:20-cr-00330-AJN Document 108 Filed 02/05/21 Page 2 of 2
The Honorable Alison J. Nathan
December 31, 2020
Page 2
Sincerely,
/s/ Christian Everdell
Christian R. Everdell
COHEN & GRESSER LLP
800 Third Avenue, 21st Floor
New York, New York 10022
(212) 957-7600
cc: All Counsel of Record (By ECF)
DOJ-OGR-00002258
Individual Pages
Page 1 - DOJ-OGR-00002257
Page 2 - DOJ-OGR-00002258
Case 1:20-cr-00330-AJN Document 108 Filed 02/05/21 Page 2 of 2
The Honorable Alison J. Nathan
December 31, 2020
Page 2
Sincerely,
/s/ Christian Everdell
Christian R. Everdell
COHEN & GRESSER LLP
800 Third Avenue, 21st Floor
New York, New York 10022
(212) 957-7600
cc: All Counsel of Record (By ECF)
DOJ-OGR-00002258