DOJ-OGR-00019976.pdf

Case 21-58, Document 39-2, 04/01/2021, 3068530, Page117 of 200 54 1 MR. COHEN: To be precise, we were urging them not to 2 return an indictment and saying we were always available to 3 speak. And, frankly, your Honor, I have been doing this kind 4 of work for 33 years, everyone knows what that means. 5 THE COURT: So you were implying -- 6 (Indiscernible crosstalk) 7 THE COURT: You were implying that, though you were 8 urging -- 9 MR. COHEN: Yes. 10 THE COURT: -- or seeking to forestall the indictment, 11 should there be an indictment, you were implying that you 12 should be contacted for voluntary surrender. 13 MR. COHEN: Yes, of course. And the day after our 14 client was arrested, we got a note from the government sending 15 the application to detention addressed to us and Haddon Morgan 16 saying your client, Ms. Maxwell, was arrested yesterday. So 17 there was no doubt that we represented her along with Haddon 18 Morgan. There was no doubt that we were available and could 19 have been contacted and worked this out. There was no doubt 20 that we are confident we would have. 21 Let me turn to the reply brief and the effort to throw 22 some more dirt on my client that we again submit should not be 23 considered as part of the governing legal standards here and 24 the precise question before the court. You heard it today and 25 in the brief we hear that at the time of her arrest, the agents SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00019976