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This legal document is a letter dated October 14, 2020, from attorney Christian R. Everdell to Judge Alison J. Nathan. Everdell argues against the government's request to delay the disclosure of evidence to his client, Ms. Maxwell, in case 1:20-cr-00330-AJN. He asserts the government has not provided sufficient legal justification, such as risks to an ongoing investigation or witness safety, and asks the court to order the immediate production of the materials to the defense.
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This is the final page (6 of 6) of a legal filing submitted on August 10, 2020, to Judge Alison J. Nathan by attorneys Mark S. Cohen and Christian R. Everdell on behalf of Ghislaine Maxwell. The document requests that Maxwell be released to the general population within the MDC (Metropolitan Detention Center) and be granted increased access to a computer terminal to review discovery materials for her defense.
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This document is the final page of a legal motion filed on August 10, 2020, by attorney Christian R. Everdell on behalf of his client, Ms. Maxwell. The motion requests that the court, presided over by Judge Alison J. Nathan, grant Maxwell's request to be released into the general population of the MDC and be given increased computer access to review discovery materials for her defense.
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This document is the final page of a legal letter dated July 27, 2020, from attorneys Christian R. Everdell and Mark S. Cohen of COHEN & GRESSER LLP to Judge Alison J. Nathan. The letter concludes a submission requesting that the Court enter a proposed protective order on behalf of their client, Ms. Maxwell. The document is part of Case 1:20-cr-00330-AJN.
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This legal document is the second page of a letter dated January 14, 2021, from attorney Christian R. Everdell to Judge Alison J. Nathan. The letter requests that the court order the Bureau of Prisons (BOP) to grant his client, Ms. Maxwell, laptop access on weekends and holidays to review millions of discovery documents for her defense. The document includes a signed order from Judge Nathan, dated January 15, 2021, granting this unopposed request.
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This is page 2 of a legal letter filed on January 25, 2021, in Case 1:20-cr-00330-AJN (Ghislaine Maxwell case). Attorneys Mark S. Cohen and Christian R. Everdell of Cohen & Gresser LLP inform Judge Alison J. Nathan that they will submit motions containing 'Confidential Information' via email for review rather than filing them immediately on the public docket, to allow the government to review proposed redactions pursuant to a Protective Order.
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Defense attorney Christian Everdell writes to Judge Alison Nathan requesting a court order compelling the BOP/MDC to allow Ghislaine Maxwell access to a laptop on weekends and holidays to review 'millions of documents' for her defense. The letter argues there are no security impediments to this request. Judge Nathan grants the unobjected-to request and orders the BOP to provide said access on January 15, 2021.
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This document is the second page of a legal letter filed on January 14, 2021, by attorney Christian Everdell to Judge Alison J. Nathan regarding United States v. Ghislaine Maxwell. The defense argues that there are no impediments to MDC staff providing Maxwell with a laptop on weekends and holidays and requests a court order forcing the BOP to grant this access to facilitate the review of 'millions of documents' for her defense.
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This legal document is a letter dated January 8, 2021, from attorney Christian R. Everdell to Judge Alison J. Nathan. Everdell requests a 30-day extension to file a notice of appeal regarding the denial of his client, Ms. Maxwell's, renewed motion for bail, arguing it would promote judicial efficiency. Judge Nathan denied the request in a handwritten note dated January 11, 2021, stating that sufficient cause for the extension had not been provided.
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This legal document is the second page of a letter dated January 8, 2021, from attorney Christian R. Everdell to Judge Alison J. Nathan. Everdell requests a 30-day extension for his client, Ms. Maxwell, to file a notice of appeal against the court's December 28, 2020 order denying her bail. The letter argues the extension would promote judicial efficiency and notes that the government objects to the request.
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This document is the second and final page of a letter dated December 31, 2020, from attorney Christian R. Everdell of the law firm Cohen & Gresser LLP to The Honorable Alison J. Nathan. The letter concludes with a standard closing and signature, and notes that all counsel of record were copied via the court's electronic filing system. The document header indicates it was filed with the court on February 5, 2020, as part of case 1:20-cr-00330-AJN, a date that precedes the letter's date, suggesting a possible clerical error in the filing stamp.
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This document is the second and final page of a legal letter dated December 31, 2020, from attorney Christian R. Everdell of the law firm Cohen & Gresser LLP. The letter is addressed to The Honorable Alison J. Nathan and was filed as part of Case 1:20-cr-00330-AJN, with copies sent to all counsel of record.
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This document is the fourth and final page of a legal filing (Document 87) for case 1:20-cr-00330-AJN, dated November 30, 2020, and filed on December 4, 2020. It contains the signature of Christian R. Everdell from the law firm Cohen & Gresser LLP, submitting the document to The Honorable Alison J. Nathan. The document also notes that copies were distributed via email to all counsel of record.
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This document is the final signature page (Page 4 of 4) of a legal filing submitted to Judge Alison J. Nathan on November 25, 2020, and filed on December 4, 2020. It is signed by Christian R. Everdell of the law firm Cohen & Gresser LLP, representing the defense in Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell). The page includes the firm's contact information and indicates that all counsel of record were copied via email.
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This is the final page (page 4) of a legal letter dated July 27, 2020, addressed to Judge Alison J. Nathan. Attorneys Christian R. Everdell and Mark S. Cohen of Cohen & Gresser LLP respectfully request that the Court enter a proposed protective order for their client, Ms. Maxwell. The document was filed on July 28, 2020, as part of Case 1:20-cr-00330-AJN.
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This legal document is a letter dated March 15, 2021, from attorney Christian R. Everdell to Judge Alison J. Nathan. The letter outlines the plan for submitting several reply memoranda, explaining that those containing confidential information will be redacted for the public docket. To facilitate this, the attorney will first submit both unredacted (under seal) and redacted versions to the Court and the government via email for review before any public filing.
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