DOJ-OGR-00002760.jpg
779 KB
Extraction Summary
3
People
3
Organizations
1
Locations
1
Events
1
Relationships
0
Quotes
Document Information
Type:
Legal document
File Size:
779 KB
Summary
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.
People (3)
| Name | Role | Context |
|---|---|---|
| Alison J. Nathan | The Honorable (Judge) |
The letter is addressed to The Honorable Alison J. Nathan.
|
| Martindell |
Mentioned in the title of a Reply Memorandum in Support of Motion.
|
|
| Christian R. Everdell | Counsel |
The author and signatory of the letter, from the law firm COHEN & GRESSER LLP.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| Government | government agency |
Mentioned multiple times in relation to a subpoena, reviewing redactions, and its Omnibus Memorandum.
|
| The Court | government agency |
Mentioned throughout as the body that will receive and give instructions on filing documents.
|
| COHEN & GRESSER LLP | company |
The law firm of the letter's author, Christian R. Everdell.
|
Timeline (1 events)
2021-03-15
Filing of a letter to Judge Alison J. Nathan regarding the submission of reply memoranda.
Court
Locations (1)
| Location | Context |
|---|---|
|
The address of the law firm COHEN & GRESSER LLP.
|
Relationships (1)
Christian R. Everdell, as counsel for a party, is writing to Judge Alison J. Nathan, who is presiding over the case (Case 1:20-cr-00330-AJN).
Full Extracted Text
Complete text extracted from the document (2,358 characters)
Case 1:20-cr-00330-AJN Document 166 Filed 03/15/21 Page 2 of 2
The Honorable Alison J. Nathan
March 15, 2021
Page 2
March 15, 2021
Page 2
11. Reply Memorandum in Support of Motion Under the Fourth Amendment, Martindell, and the Fifth Amendment to Suppress All Evidence Obtained from the Government’s Subpoena to [REDACTED] and to Dismiss Counts Five and Six
12. Reply Memorandum in Support of Motion to Dismiss Counts One through Four of the Superseding Indictment for Lack of Specificity
12. Reply Memorandum in Support of Motion to Dismiss Counts One through Four of the Superseding Indictment for Lack of Specificity
Several of the reply memoranda reference or discuss Confidential Information produced in discovery and are therefore redacted pursuant to paragraph 15 of the Protective Order (Dkt. 36). In order to give the government the chance to review the proposed redactions, we will not file on the public docket any reply memoranda that contain redactions until we are instructed to do so by the Court.¹
The remaining reply memoranda do not contain any redactions. However, we are mindful of the fact that the government’s Omnibus Memorandum in Opposition to the Defendant’s Pre-trial Motions, to which the reply memoranda respond, has not yet been filed on the public docket. Accordingly, we will also refrain from filing the reply memoranda that do not contain redactions on the public docket until we are instructed to do so by the Court.
Instead, we will submit by email to the Court and the government all of the reply memoranda and exhibits pursuant to Rule 2(B) of the Court’s individual rules of criminal practice. For the reply memoranda and exhibits that contain redactions, we will submit two versions – an unredacted original to be kept under seal and a version for public filing with proposed redactions.
Please contact us with any questions. Your consideration is greatly appreciated.
Respectfully submitted,
/s/ Christian R. Everdell
Christian R. Everdell
COHEN & GRESSER LLP
800 Third Avenue, 21st Floor
New York, New York 10022
(212) 957-7600
Christian R. Everdell
COHEN & GRESSER LLP
800 Third Avenue, 21st Floor
New York, New York 10022
(212) 957-7600
cc: All counsel of record (via email)
¹ For documents that the government has designated as “Confidential,” we have preliminarily indicated that they be filed under seal, as required by paragraph 15 of the Protective Order. However, because some of the exhibits are “judicial documents,” we intend to propose that those “Confidential” designations be amended consistent with our March 9, 2021 letter to the Court.
DOJ-OGR-00002760
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