This is an email from Christian Everdell, one of Ghislaine Maxwell's defense attorneys, to Judge Alison Nathan's chambers regarding a typographical error in Maxwell's renewed bail motion reply brief.
On December 23, 2020, defense attorney Christian Everdell sent an email to Judge Nathan's chambers notifying the court of a typographical error discovered in Ghislaine Maxwell's reply brief for her renewed bail application (Case 20 Cr. 330). The email indicates that the government had no objection to filing a corrected version, and includes both redacted and unredacted versions of the revised memorandum with corrections on pages i and 8. This is a routine procedural communication during Maxwell's pre-trial detention.
From: Christian Everdell To: "[email protected] Cc: ' C STERNHEIM"' 'Jeff Pagliuca' 'Laura Menningee Subject: RE: U.S. v. Ghislaine Maxwell, 20 Cr. 330 (AJN) -- Renewed Bail Motion Reply Memorandum and Exhibits (to be Filed Under Seal) Date: Wed, 23 Dec 2020 18:08:04 +0000 Attachments: Reply_Memorandum_re_Renewed_Bail_Application_Final.pdf; Reply_Memorandum_re_Renewed_Bail_Application_Final_Redacted.pdf Inline-Images: image001.jpg; image002.jpg; image004.jpg; image006.jpg Dear Judge Nathan — In preparing to file the reply brief pursuant to the Court's order (Dkt. 101), we noticed a typographical error in the reply dilie um. We have spoken to the government and they have no objection to the defense making this revision (on pages i and 8) before filing the memorandum on the public docket. Accordingly, attached to this email are revised versions of the unredacted and redacted memorandum reflecting this change. We will file the revised redacted version on the docket today. We apologize for the error. Regards, Christian R Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 view bio www.cohengresser.com New York I Pans I Washington DC I London CONFIDENTIALITY NOTICE: The information contained in this e-mail may be confidential and/or privileged. This e-mail is intended to be reviewed initially by only the individual named above. II the reader of this e-mail is not the intended recipient or a representative of the intended recipient. you are hereby notified that any review. dissemination or copying of this e-mail or the information contained herein is prohibited. If you have received this e-mail in error. please immediately notify the sender by telephone and permanently delete this e-mail. Thank you. PRIVACY: A complete copy of our privacy policy can be viewed a! Si oslAwnv.cOhengroSSercom/privaCV-Paqt From: Christian Everdell Sent: Friday, December 18, 2020 7:40 PM To: [email protected] EFTA00015975
Cc: '; (USANYS)'; Mark S. Cohen; 'BOBBI C STERNHEIM'; 'Jeff Pagliuca'; 'Laura Menningee Subject: U.S. v. Ghislaine Maxwell, 20 Cr. 330 (AJN) -- Renewed Bail Motion Reply Memorandum and Exhibits (to be Filed Under Seal) Dear Judge Nathan — Attached please find the following documents submitted to the Court and all counsel under seal pursuant to the Court's order (Dkt. 89): 1. Cover letter 2. Reply memorandum (unredacted) 3. Reply memorandum (redacted) 4. Accompanying exhibits A-B Regards, Christian R Everdell COHEN & GRESSER LLP 800 Third Avenue New York. NY 10022 view bio www.cohengresser.com New York I Paris I Washington DC I London CONFIDENTIALITY NOTICE: The information contained in this e-mail may be confidential and/or privileged. This e-mail is intended to be reviewed initially by only the individual named above. If the reader of this e-mail is not the intended recipient or a representative of the intended recipient. you are hereby notified that any review. dissemination or copying of this e-mail or the information contained herein is prohibited. If you have received this e-mail in error. please immediately notify the sender by telephone and permanently delete this e-mail. Thank you. PRIVACY: A complete copy of our privacy policy can be viewed .i! htlpslAvww.cohenoresser.com/privackpolicx EFTA00015976



