DOJ-OGR-00019976.jpg

be N Ww ws Oo OY ~] oO Ke) a fan) = be N Ww = Hs Oo a OY a ~] a oO a Ke) 20 21 22 23 24 25 Case 21-58, Document 39-2, 04/01/2021, 3068530, Page117 of 200 54 k7e2MaxC k je MR. COHEN: To be precise, we were urging them not to return an indictment and saying we were always available to speak. And, frankly, your Honor, I have been doing this kind of work for 33 years, = THE COURT: So you were implying -- =~ THI! urging -- MI Indiscernible crosstalk) ical R. COHEN: Yes. everyone knows what that means. COURT: You were implying that, though you were HE COURT: -- or seeking to forestall the indictment, should there be an indictment, you were implying that you should be contacted for voluntary surrender. MR. COHEN: Yes, of course. And the day client was after our arrested, we got a note from the government sending the application to detention addressed to us and Haddon Morgan saying your client, Ms. Maxwell, was arrested yesterday. So there was no doubt that we represented her along with Haddon Morgan. There was no doubt that we were available and could have been contacted and worked this out. There was no doubt that we are confident we would have. Let me turn to the reply brief and the ef Fort to throw some more dirt on my client that we again submit should not be considered as part of the governing legal standards here and the precis question before the court. You heard in the briet SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 it today and we hear that at the time of her arrest, the agents DOJ-OGR-00019976