November 23, 2021¶
BY E-MAIL to NathanNYSDChambers@nysd.uscourts.gov The Honorable Alison J. Nathan United States District Judge Southern District of New York 40 Foley Square New York, New York 10007¶
VILLAZOR¶
USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC DATE FILED: 11/24/21¶
Re: United States it Maxwell, No. 20 Cr. 330¶
Dear Judge Nathan:¶
Vittozor LLP 250 West 55th Street. 30th Floor New York. NY 10019 www.snethe Ilozor.corn¶
J.= 212 582 4400
¶
patrick smith asmtthollozor.con¶
The parties are ORDERED to docket any proposed redactions to this memo¶
endorsement and Administrator¶
letter by close of business¶
on November 24, 2021. The Court will not extend the deadline for the parties’ proposed protective order, which must be submitted by 12:00¶
p.m. today. SO ORDERED.¶
We represent Jordana H. the independent administrator of the Epstein Victims’ Compensation Program. We write regarding the Court’s order, dated November 22, 2021, denying motion to quash Maxwell’s subpoena to her and ordering production of the subpoenaed documents by November 24, 2021 at noon.¶
intends to comply with the Court’s order and produce responsive documents to the Court. However, given the volume of materials and the steps necessary to ensure that documents produced fall within the scope of the subpoena, it is not possible to produce all materials by noon tomorrow. We understand that the volume of potentially responsive materials is approximately 6,000 to 7,000 pages, and we note that the original return date for the subpoena was November 29, 2021 at 8:30am.¶
We intend to roduce b noon tomorrow We Intel’ r to pro r uce remaining responsive ocuments as soon as posse e ere er and respectfully request until November 29, 2021 at 8:30am (the original subpoena return date) to complete production. SO ORDERED.¶
We are available should the Court have any questions.¶
Respectfully submitted,¶
/s/_./¶
11/24/21¶
E J. Villazor LLP¶
cc: AUSA Alison Moe, AUSA Mattrene Comey, AUSA Andrew Rohrbach, AUSA Lam Pomerantz, Christian R. Everdell, Esq., Jeffrey S. Pagliuca, Esq., Laura A. Memainger, Esq., Mark Stewart =, Esq., Bobbi C. Steruheim, Esq. (by e-mail)¶