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efta-efta00010164DOJ Data Set 8Correspondence

EFTA00010164

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DOJ Data Set 8
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EFTA Disclosure
Text extracted via OCR from the original document. May contain errors from the scanning process.
From: ' To: Christian Everdell Cc: Jeff Pagliuca , Laura Menninger 'BOBBI C STERNHEIM' Subject: RE: Pseudonyms Date: Wed, 10 Nov 2021 01:33:57 +0000 Attachments: 2021-1 I -10,Jetter_re_pseudonyms_and_sealing.pdf; Exhibit_A.pdf Inline-Images: image001.gif; image003.jpg All, Attached is a draft of the letter regarding the logistics relating to pseudonyms. There is a section for your position, so if you could please send us the language you'd like us to add by tomorrow evening, we can finalize and file it. Thanks, From: Christian Everdell Sent: Tuesday, November 9, 2021 11:23 AM To: I *c .>; (USANYS) Cc: Jeff Pagliuca Subject: [EXTERNAL] RE: Pseudonyms ; Laura Menninger < ; 'BOBBI C STERNHEIM' Yes, let's do that. I'll put them to the attention of From: Sent: Tuesday, November 9, 202111:16 AM To: Christian Everdell Cc: Jeff Pagliuca (USANYS) Subject: RE: Pseudonyms ; Laura Menninger 'BOBBI C STERNHEIM' Thanks, Chris. Since I'm not sure exactly where we'll be in the morning, and I don't want to delay you at all in the morning, it mike make sense to just drop them at the security tent at our office, which is next door. Would that work? From: Christian Everdell Sent: Tuesday, November 9, 202110:52 AM To: I (USANYS) <a; Cc: Jeff Pagliuca > ; Laura Menninger <a); 'BOBBI C STERNHEIM' Subject: [EXTERNAL] RE: Pseudonyms EFTA00010164 Thanks, I can try to bring the hard drives to the hearing (we have 4 to give you). I should be able to bring them in, but maybe it's better to have a paralegal meet me in front of the side entrance of 40 Foley at 8:30am. I can hand them off. From: Sent: Tuesday, November 9, 2021 10:42 AM To: Christian Everdell (USANYS) Cc: Jeff Pagliuca cz :; Laura Menninger ; 'BOBBI C STERNHEIM' Subject: RE: Pseudonyms Hi Chris, Not a problem, we're aiming to send you the letter later today that addresses all of those issues. Separately, could you please bring extra drives to the hearing, along the lines we've discussed? If it's easier to mail them (or if it would be an issue to bring them past security), that's fine too. Thanks, From: Christian Everdell < Sent: Tuesday, November 9, 2021 10:40 AM To: (USANYS) >; Cc: Jeff Pagliuca Subject: [EXTERNAL] Pseudonyms and >; ; Laura Menninger < ; 'BOBBI C STERNHEIM' According to my notes, the following three joint letters regarding pseudonyms are due to the court tomorrow: 1. Joint letter (filed under seal) re: pseudonyms used by witnesses 2. Joint letter (filed on ECF) re: limiting instruction re: pseudonyms 3. Joint letter (filed on ECF) re: procedures w/r/t pseudonyms to be used at voir dire and sealing/redacting exhibits at trial Please send us your proposals by COB today. Jeff and Laura are traveling today for the hearing and we need the chance to discuss your proposals with them tonight when they arrive. Thanks, Chris Christian R Everdell COHEN & GRESSER LLP EFTA00010165 800 Third Avenue New York, NY 10022 view bio www.cohengresser.com New York I Paris I Washington DC I London CONFIDENTIALITY NOTICE: The information contained in this e-mail may be confidential and/or ptivileged. This e-mail is intended to be 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 amt. 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 .i! httpslAvww.cohenctresser.com/privacK-policy EFTA00010166

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Ghislaine Maxwell's defense team filed a motion to dismiss Counts One through Four of the superseding indictment for lack of specificity. The motion was filed on January 25, 2021, in the United States District Court for the Southern District of New York. The defense team is represented by multiple attorneys from different law firms.

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DOJ Data Set 9OtherUnknown

To: Laura Menninger

From: To: Laura Menninger " Cc: Jeff Pa 'lima •, "Christian R Everdell - Cohen & Gresser LLP , 'BOBBI C STERNHEIM' Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Discovery request Date: Tue, 30 Mar 2021 02:32:42 +0000 Attachments: 2021-03-29_Letter_Re_Discovery_Requests_Re_FOIA.pdf Inline-Images: image001.jpg Counsel, Please see the attached correspondence. Best, Assistant United States Attorney Southern District of New York One Saint Andrew's Plaza New York, NY 10007 From: Laura Menninger Sent: Monday, March 8, 2021 2:00 PM To: >; Cc: Jeff Pagliuca <1 >; Christian R Everdell - Cohen & Gresser LLP 'BOBBI C STERNHEIM' < Subject: US v. Maxwell - 20 Cr. 330 (AJN) - Discovery request Counsel: Please see attached correspondence of today's date. -Laura Laura A. Menninger Haddon, Morgan and Foreman, P.C. 150 East 10th Avenue Denver, Colorado 80203 EFTA00078954 www.hmflaw.com CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previo

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Court UnsealedLegal FilingUnknown

Court Filing - Notice of Electronic Filing: 21-2

The document is a notice of electronic filing from the US District Court, Southern District of New York, indicating that the appeal record in USA v. Maxwell has been transmitted to the US Court of Appeals. It includes details about the case, the charges against Ghislaine Maxwell, and the attorneys involved. The case involves charges of conspiracy, enticement, and transportation of minors for illegal sex acts, among others.

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DOJ Data Set 8CorrespondenceUnknown

EFTA00019897

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EFTA00031906

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