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efta-efta00028272DOJ Data Set 8Correspondence

EFTA00028272

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DOJ Data Set 8
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efta-efta00028272
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EFTA Disclosure
Text extracted via OCR from the original document. May contain errors from the scanning process.
From: USANYS)" To. USANYS) [Contractor]" Subject: RE: Defense Rule 16 Disclosure Date: Thu, 11 Nov 2021 22:56:42 +0000 Attachments: 2021.11.08 Letter to Government re Rule 16 Disclosure.PDF Thank you for doing this. The defense's November 8 letter (attached) lists a bunch of Government discovery in 12 subcategories. Could you please take a look at the letter and put copies of the bates numbers the defense has identified and put them in subfolders in the folder that created (e.g., AT&T, Federal Express, etc). I added a subfolder as an example. Let me know if you have any questions. Thanks! From: USANYS) [Contractor] Sent: Tuesday, November 9, 202112:51 PM To Cc: (USANYS) [Contractor] Subject: RE: Defense Rule 16 Disclosure (USANYS) Thanks I Saved here: \ Usa.doj.gov \cloud \ NYS \StAndrewASharecAUSvEpstein-2018R01618Wiscovery \ GM \ Defense Rule 16 Disclosures \ 2021.11.08 Defense Rule 16 Disclosure From: Sent: Tuesday, November 9, 2021 12:44 PM To: USANYS) [Contractor] Cc: USANYS) [Contractor] (USANYS) u ject: Re: Defense Rule 16 Disclosure In the discovery folder. Thanks! On Nov 9, 2021, at 12:25 PM, (USANYS) [Contractor] wrote: Hi team — apologies for just getting to this now. Where on the shared would you like these saved? Thanks! From: Sent: Monday, November 8, 2021 9:40 PM To: SANYS) [Contracto (USANYS) [Contractor] Cc: (USANYS) EFTA00028272 Subject: FW: Defense Rule 16 Disclosure Hi .—could you please save these on the shared? Thanks! Sent: From: Christian Everdell Monday, November To: (USANYS) Cc: Jeff Pag luta < Subject: (EXTERNAL) Defense Rule 16 Disclosure and. Attached is the defense Rule 16 disclosure. Regards, Chris Christian R Everdell <image001.gif> I view bio www.cohengresser.com New York I Paris I Washington DC I London <image002.jpg> CONFIDENTIALITY NOTICE: The information contained in this e-mail may be confidential and/or privileged. This e-mail is intended robe reviewed initially by only the individual named above. If the reader of this e-mail is not the intended recipient or a representative of the intended recipient. you are hereby notified that any review. dissemination or copying of this e-mail or the information contained herein is prohibited. If you have received this e-mail in error. please immediately notify the sender by telephone and permanently delete this e-mail. Thank you. PRIVACY: A complete copy of our privacy policy can be viewed al: httpsikewre.cohengressercom/privacpolicx EFTA00028273

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Related Documents (6)

DOJ Data Set 8CorrespondenceUnknown

EFTA00019897

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Court UnsealedLegal FilingUnknown

Court Filing: 133

Ghislaine Maxwell's defense team files a motion to suppress evidence obtained from a government subpoena and to dismiss Counts Five and Six of the indictment, citing the Due Process Clause. The motion is supported by a memorandum of law and exhibits. The defense attorneys representing Maxwell are listed, along with their contact information.

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House OversightLegal FilingUnknown

Defense attorney Christian R. Everdell requests that the court order the MDC to accept two hard driv...

Defense attorney Christian R. Everdell requests that the court order the MDC to accept two hard drives containing non-Highly Confidential discovery materials for Ghislaine Maxwell's use. The hard drives are organized in a user-friendly format, and the government does not object to the request. The MDC Legal Department has expressed concerns and is given the opportunity to note objections.

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Court UnsealedLegal FilingUnknown

Declaration in Support of Motion to Withdraw as Co-Counsel: 798-1

Christian R. Everdell of Cohen & Gresser LLP declares that the firm is withdrawing as co-counsel for Ghislaine Maxwell with her consent, as Markus Moss PLLC has taken over her representation for the government's motion to unseal grand jury transcripts. Cohen & Gresser LLP represented Maxwell during her trial and sentencing but not in her appellate proceedings. The firm will share its files with Markus Moss PLLC upon request.

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Court UnsealedCorrespondenceUnknown

Court Filing - Letter to Judge: Case1:20-cr-03320-AJN Document 292 Filed 08/27/20 Page 20 of 1164

The defense attorneys for Ghislaine Maxwell request a protective order from Judge Alison J. Nathan to govern the handling of discovery materials. The parties have reached agreement on most provisions but remain at odds over restrictions on government witnesses and the disclosure of alleged victim identities.

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Court UnsealedLegal FilingUnknown

Court filings: 8

The documents include court filings related to the cases of Ghislaine Maxwell and Jeffrey Epstein. The first filing concerns the scheduling of Maxwell's arraignment and bail hearing, while the second is related to Epstein's bail motion and financial disclosure.

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