Case 1:20-cr-00330-AJN Document 86 Filed 12/04/20 Page 1 of 4
800 Third Avenue
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COHEN & GRESSER LLP +1 212.957 7600 phone
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Mark S. Cohen
Christian R. Everdell
+1 (212) 957-7600
[email protected]
[email protected]
November 25, 2020
TO BE FILED UNDER SEAL
VIA EMAIL (SUBMITTED PURSUANT TO SECTION 2(B)
OF JUDGE NATHAN’S INDIVIDUAL PRACTICES IN CRIMINAL CASES)
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
AO 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 plan to file a Renewed Motion for
Release on Bail (the “Motion”) and respectfully request an in camera conference, with all
counsel present, to address the appropriate procedures for the filing and consideration of the
Motion. For the reasons explained below, we intend to request, pursuant to Fed. R. Crim. P.
49.1(d), that the Court permit the filing of portions of the Motion and certain supporting
materials under seal and require that any responsive materials be filed under seal. We believe an
in camera conference would be the most efficient form to address these issues and other
confidentiality concerns related to the Motion. We intend to provide a full set of materials to the
government, Pretrial Services, and the Court when the Motion is filed. We are merely requesting
that sensitive contents of the submission be accorded confidentiality protections similar to those
that the government routinely requires in protective orders, including the one in this case.
In the four months since this Court denied Ms. Maxwell’s request for bail and granted the
government’s motion for detention, Ms. Maxwell and her counsel have assembled substantial
information that was not available to present at the initial hearing, as well as a comprehensive
bail package co-signed by sureties who were unable to come forward at that time. Accordingly,
Ms. Maxwell now seeks to renew her request for bail pursuant to 18 U.S.C. § 3142(f).
Ms. Maxwell’s renewed application will rely on sensitive and private information that, if
made public, would be highly damaging to both Ms. Maxwell and third parties, including:
* Letters from Ms. Maxwell’s family members and close friends, who have agreed to
serve as sureties to support Ms. Maxwell’s renewed bail application. The letters
contain personal details that, if made public, would invite identification and
DOJ-OGR-00001851