From: Christian Everdell
To: "NathanNYSDChambers@nysd.uscourts.govm
Cc: '
C STERNHEIM"' 'Jeff Pagliuca'
'Laura Menningee
Subject: RE: U.S. v. Ghislaine Maxwell, 20 Cr. 330 (AJN) -- Renewed Bail Motion Reply
Memorandum and Exhibits (to be Filed Under Seal)
Date: Wed, 23 Dec 2020 18:08:04 +0000
Attachments: Reply_Memorandum_re_Renewed_Bail_Application_Final.pdf;
Reply_Memorandum_re_Renewed_Bail_Application_Final_Redacted.pdf
Inline-Images: image001.jpg; image002.jpg; image004.jpg; image006.jpg
Dear Judge Nathan —
In preparing to file the reply brief pursuant to the Court's order (Dkt. 101), we noticed a typographical error in the reply
um.
dilie We have spoken to the government and they have no objection to the defense making this revision (on pages i
and 8) before filing the memorandum on the public docket. Accordingly, attached to this email are revised versions of the
unredacted and redacted memorandum reflecting this change. We will file the revised redacted version on the docket
today. We apologize for the error.
Regards,
Christian R Everdell
COHEN & GRESSER LLP
800 Third Avenue
New York, NY 10022
view bio
www.cohengresser.com
New York I Pans I Washington DC I London
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From: Christian Everdell
Sent: Friday, December 18, 2020 7:40 PM
To: ihlathanNYSDChambers@nysd.uscourts.govi
EFTA00015975
Cc: '; (USANYS)'; Mark S. Cohen; 'BOBBI C
STERNHEIM'; 'Jeff Pagliuca'; 'Laura Menningee
Subject: U.S. v. Ghislaine Maxwell, 20 Cr. 330 (AJN) -- Renewed Bail Motion Reply Memorandum and Exhibits (to be Filed
Under Seal)
Dear Judge Nathan —
Attached please find the following documents submitted to the Court and all counsel under seal pursuant to the Court's
order (Dkt. 89):
1. Cover letter
2. Reply memorandum (unredacted)
3. Reply memorandum (redacted)
4. Accompanying exhibits A-B
Regards,
Christian R Everdell
COHEN & GRESSER LLP
800 Third Avenue
New York. NY 10022
view bio
www.cohengresser.com
New York I 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 .i! htlpslAvww.cohenoresser.com/privackpolicx
EFTA00015976