212-243-1100 • Main 917-306.6666 • Coll 888-587-4737 • Fax¶
Honorable Alison J. Nathan United States District Court United States Courthouse 40 Foley Square New York, NY 10007¶
Dear Judge Nathan:¶
33 West 19th Street - 4th Floor Now York, New York 10011 bc@srornholmlow.com¶
March 16, 2021¶
Re: United States v. Ghislaine Maxwell 20 Cr. 330 (AJN)¶
On behalf of our client, Ghislaine Maxwell, we respectfully submit the Reply Memorandum of Ghislaine Maxwell in Support of Her Third Motion for Bail (the “Bail Reply”) and accompanying exhibit. The Bail Reply contains references to the government’s Omnibus Memorandum in Opposition to Ms. Maxwell’s Pre-trial Motions (the “Pretrial Motion Opposition”) for which a ruling regarding redactions is pending. Until these redactions are finalized, we are uncertain whether any redactions to the Bail Reply will be necessary.¶
For now, we hereby submit by email to the Court and government the unredacted Bail Reply pursuant to Rule 2(B) of the Court’s individual rules of criminal practice. Should any redactions to the Bail Reply be required after the Court rules on the redactions to the Pretrial Motion Opposition, we will at that time submit two versions of the Bail Reply to the Court: an unredacted original to be filed under seal and a version for public filing containing the required redactions.¶
Please contact me with any questions. Your consideration of this request is greatly appreciated.¶
Very truly yours,¶
/s/¶
BOBBI C. STERNHEIM¶
cc: Counsel for all parties¶