Confirming the letter regarding the trial date was filed on ECF.
Following up on status of conferral emails as joint letter is due.
Asking for an ETA on the letter.
Stating parties agree on Nov 2021 but disagree on the week. Government refuses Nov 8th due to counsel continuity and witness availability.
Arguing against Nov 29 date due to holiday interference and negative impact on defense. Proposing Nov 15 as accommodation but preferring Nov 8. Refusing speedy trial exclusion beyond 11/8.
Stating availability to begin Nov 8. Noting Laura Menninger has a civil trial Dec 13.
Proposing Nov 29, 2021 trial date based on witness/counsel availability. Proposing deadline for victim identity disclosure (3 months prior) and expert disclosures (2 months prior).
Requesting complete picture of available dates for balance of 2021.
Stating preferred date is 11/8 due to Maxwell's detention conditions. Offering flexibility if she is released on bail.
Clarifying they need scheduling availability separate from preferences.
Initial inquiry to confer about trial dates from Sept 2021 through end of year.
Asking for Government availability for 11/8.
Government informing the court about victim attendance for the upcoming arraignment. Victim-2 attending by phone; Boies and McCawley attending in person.
Discussing three issues regarding the wording of a letter to the Court about producing redacted notes to the defense and AEO designations.
Sending a draft letter for Judge Torres and asking for thoughts.
Sending unredacted and redacted copies of notes; stating intention to produce redacted notes to defense and client name on AEO basis.
Rejecting proposed redactions and suggesting Patel file a motion under seal before Judge Torres.
Proposing a disclosure cover letter modeled on US v. Madonna; arguing the material is not Brady/3500/Rule 16; mentioning surveillance video contradicts client's error.
Requesting a copy of the disclosure being considered for Mr. [Redacted].
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