Case 1:20-cr-00330-PAE Document 273 Filed 05/07/21 Pagei1ofi
800 Third Avenue
COHEN & GRESSER LLP New York, NY 10022
+1 212.957 7600 phone
www.cohengresser.com
Christian R. Everdell
+1 (212) 957-7600
[email protected]
May 7, 2021
VIA ECF
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 will be filing our Omnibus Memorandum
in Support of Ms. Maxwell’s Supplemental Pretrial Motions Relating to the S2 Superseding
Indictment with accompanying exhibits.
The memorandum and exhibits contain 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 supplemental motions on the public docket until we are
instructed to do so by the Court. Instead, we will submit the supplemental motions 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 1t deems necessary.
Please contact us with any questions. Your consideration is greatly appreciated.
Respectfully submitted,
/s/ Christian R. Everdell
Christian R. Everdell
COHEN & GRESSER LLP
800 Third Avenue, 21st Floor
New York, New York 10022
(212) 957-7600
cc: All counsel of record (via email)
DOJ-OGR-00004110