EFTA00075351.pdf

COHEN & GRESSER LLP Christian R. I.:verde!' July 6, 2020 VIA ECF The Honorable Alison J. Nathan United States District Court Southern District ofNew York nited States Courthouse Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: On behalf of our client, Ghislaine Maxwell, we respectfully submit this letter in response to the Court's order from earlier today regarding the scheduling of the arraignment, initial appearance, and bail hearing in this matter. We have been attempting to contact our client at the Metropolitan Detention Center; we were able to speak to her for the first time today just before 9:00pm this evening. She has agreed to waive her physical presence for these proceedings. As directed by the Court, we have met and conferred with the Government regarding scheduling. All parties will be able to proceed remotely on the morning of July 14, 2020. The defense will not be able to proceed on July 9, 2020. We will meet and confer further with the Government tomorrow regarding a proposed briefing schedule and anticipate providing a joint proposed briefing schedule for the Court's consideration by the end of the day. Respectfully submitted, Is/ Mark S. Cohen Mark S. Cohen Christian R. Everdell EFTA00075351 The Honorable Alison J. Nathan July 6, 2020 Page 2 New York, New York 10022 (212) 957-7600 cc: Mk e-mail) (by e-mail) (by e-mail) EFTA00075352