Attached is our letter to Judge Nathan. We will file before 9pm unless we hear otherwise from you.¶
Thanks,¶
Chris¶
Sent: Monday, July 06, 2020 5:36 PM¶
To: Christian Everdell; Mark S. Cohen¶
Subject: RE: SDNY indictment¶
Chris and Mark,¶
In light of Judge Nathan’s order, are you available for a call this evening to discuss scheduling? We are available at 6, if that works for you.¶
Thanks,¶
Chris,¶
Ms. Maxwell’s BOP number is . My understanding is that she has arrived in SDNY and will be housed at the MDC.¶
EFTA00084336¶
I will send an email connecting you with Pretrial Services shortly.¶
Can you tell me what Ms. Maxwell’s BOP number is? She is not in the BOP system yet.¶
Thanks,¶
Chris¶
Subject: RE: SDNY indictment¶
Attached please find a copy of the letter we just filed on ECF.¶
Thanks,¶
We can make that work, thanks. We will note in the letter that the parties propose the defense submission be due at 3pm on Thursday, any reply be due at 12pm on Friday, and the court appearance take place Friday afternoon.¶
EFTA00084337¶
We will need until 3pm on Thursday. Let us know if that’s a problem.¶
Thanks,¶
Chris¶
Sent from my iPhone¶
On Jul 5, 2020, at 6:40 PM,¶
Understood, thanks. Would you agree to a 12pm Thursday deadline for your submission, and a 12pm Friday deadline for any written response from us, followed by the arraignment and bail hearing Friday afternoon? If so, we’ll propose that to the Court.¶
We will reach out to Pretrial Services tomorrow to arrange for an interview.¶
Thanks, . We are planning to make a bail submission on Thursday, subject to being able to communicate with our client. So we will need your help to arrange an interview with Pretrial Services.¶
Thanks Chris. We will request that the arraignment take place this Friday and will note your consent.¶
Are you planning to file a written submission in support of a bail application in advance of Friday? If so, would it make sense for us to include a proposed briefing schedule in our letter?¶
Along those same lines, please let us know if you need assistance coordinating an interview with Pretrial Services, which will need to take place in advance of any bail application.¶
EFTA00084338¶
We would prefer that the arraignment take place on Friday, rather than Wednesday, and will consent to an exclusion of speedy trial time until Friday. I don’t think a call is necessary, but let me know if you want to discuss.¶
Thanks,¶
Chris¶
Subject: RE: SDNY indictment¶
Chris and Mark,¶
We are planning to submit a letter to Judge Nathan this evening informing her that the Marshals expect Ms. Maxwell to arrive in SDNY in time for a court appearance this Wednesday, requesting that the Court schedule an arraignment, and requesting the exclusion of time through the arraignment date. We intend to seek the exclusion of time both for the transportation of the defendant from another district and to allow for us to discuss the terms of a protective order to cover discovery in this case.¶
If possible, we would like to include your views in that letter. Would you please let us know whether you have any preferences on scheduling and whether you will consent to the exclusion of speedy trial time?¶
We are also happy to have a call if that would be useful.¶
Thanks,¶
On Jul 3, 2020, at 11:44 AM, Christian Everdell¶