Maxwell defense letter to Judge Nathan on filing sealed reply brief, May 2021

COHEN & GRESSER LLP¶

800 Third Avenue New York, NY 10022¶

www.cohengresser.com¶

May 28, 2021¶

VIA ECF¶

The Honorable Alison J. Nathan¶

United States District Court¶

Southern District of New York¶

40 Foley Square¶

New York, New York 10007¶

Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)¶

Dear Judge Nathan:¶

On behalf of our client, Ghislaine Maxwell, we will be filing our Omnibus Reply Memorandum in Support of Ms. Maxwell’s Supplemental Pretrial Motions Relating to the S2 Superseding Indictment.¶

The reply memorandum contains Confidential Information produced in discovery that is governed by paragraph 15 of the Protective Order (Dkt. 36). Accordingly, pursuant to our prior practice, we will not file the reply memorandum on the public docket until we are instructed to do so by the Court. Instead, we will submit the reply memorandum by email to the Court and the government under seal—pursuant to Rule 2(B) of the Court’s individual rules of criminal practice—to give the government the opportunity to propose and justify any redactions it deems necessary.¶

Please contact us with any questions. Your consideration is greatly appreciated.¶

Respectfully submitted,¶

/s/ Christian R. Everdell¶

Christian R. Everdell¶

cc: All counsel of record (via email)¶

COHEN & GRESSER LLP¶

800 Third Avenue, 21st Floor¶

New York, New York 10022¶

EFTA00104410¶