EFTA00076152.pdf

USDC SDNY Smith Villazor LLF. DOCUMENT ELECTRONICALLY FILED New York, New York 10019 DOC 0: www.smithvillazor.com DATE FILED: 11/15/21 Patrick J. Smith may file a motion to quash SMITH VILLAZOR the subpoena on or before Friday, November 19, 2021. The motion should not repeat arguments made in the November 15, 2021 Government's motion to quash, which is due on Thursday, November 18, 2021. BY E-MAIL to The Defense shall respond to both The Honorable Alison J. Nathan motions on or before Monday, United States District Judge Southern District of New York November 22, 2021. This memo endorsement is filed temporarily under New York, New York 10007 seal to allow the parties to propose redactions. Any redactions to this letter Re: United States v. Maxwell, No. 20 Cr. 330 and the Defendant's motion must be filed on the docket by November 21, Dear Judge Nathan: 2021. SO ORDERED. We represen the independent admircstrator of the Epstein Victims' Am* Compensation Program, t to It:gat:on-a ternative program established to confidentially resolve 11/15/21 claims of sexual abuse against Jeffrey Epstein, his Estate, and other related individuals and entities. This afternoon we were informed by counsel for the government that the defendant has sought, and the Court intends to authorize, a subpoena directed ti under Federal Rule of Criminal Procedure 17(c) for certain documents. We • the Court that we are authorized to plumjsriltejlf the subpoena on behalf o and (ii) request a briefing schedule for nticipated motion to quash the subpoena. We understand that the government intends to file a motion to quash the subpoena, with a deadline of this Wednesday, November 17, 2021. Given that we have just learned of the subpoena today, the issues it presents, and mindful of the impending start date of trial we respectfully request until November 23, 2021 to file a motion to quash on behalf. We are available should the Court have any questions. Respectfully submitted, /s/ Patrick J. Smith Patrick J. Smith Smith Villazor LLP cc: Christian R. Everdell, Esq., Jeffrey S. Pagliuca, Esq., Laura A. Menninger, Esq., Mark Stewart Cohen, Esq., Bobbi C. Stemheim, Esq. (by e-mail) EFTA00076152