EFTA00016716

To: Laura Mennin er tennin e

From: To: Laura Mennin er tennin e mflaw.com>, " " • (USANYS)" Cc: Jeff Pagliuca [email protected]>, "Christian R Everdell - Cohen & Gresser LLP ([email protected])" <[email protected]>, 'BOBBI C STERNHEIM' <[email protected]> Subject: RE: US v. Maxwell - 20 Cr. 330 (MN) - Request to view evidence, highly confidential materials, scenes Date: Sat, 27 Mar 2021 22:38:06 +0000 Inline-Images: image001.jpg Counsel, Thank you for your email. Below please find our response. If this is acceptable to you, then we will proceed with arranging the logistics of having your client produced to 500 Pearl the week of April 12th and the week April 19th. We will also arrange for the FBI to transport evidence to 500 Pearl for review the week of April 12rh. Physical Evidence • It is not reasonable or feasible to insist that the FBI bring all physical evidence to 500 Pearl Street. That said, we are certainly willing to work with you to ensure that your client can revi

Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential

From: To: ' )" C )" C Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes Date: Mon, 15 Mar 2021 23:14:14 +0000 Inline-Images: image001.jpg -notes from call with in red below. From: Sent: Thursday, March 11, 20218:20 PM To:'- (NYPD)' Cc: N. (NY) (FBI) ) `z >; (USANYS) Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes Following up on this, we had a call with defense counsel, who asked a number of questions I couldn't answer. Would you please let me know the answers to the below? For the nude/partially nude highly confidential images: • How many highly confidential images are there in total, including both from the discs and from the devices? From the devices approximately 2,100 images/videos (cellebrite is on there) From the discs you previously reviewed them all (3,459), please let us know if you want us to provide to you. Small number of nud

EFTA00025278

Affidavit: 149

The affidavit, filed by Bobbi C. Sternheim, Esq., confirms that defense counsel for Ghislaine Maxwell attempted to resolve issues related to a Motion for a Bill of Particulars and Pretrial Disclosures with government counsel, but were unable to reach an agreement. The affidavit is a required step under Local Criminal Rule 16.1.

(USANYS) [Contractor]"

From: To: ' Cc: " (USANYS) [Contractor]" s-M > (USANYS)" (USANYS) [Contractor)" Subject: RE: US v. Maxwell - [conferral re photo and other discovery deficiencies] Date: Wed, 11 Aug 2021 21:33:23 +0000 Attachments: Maxwell_problem_filess images_Not_Exported.xlsx Hi again, Good news, was able to run searches for those last 200 files way more quickly than anticipated. Let me know what you think of the attached spreadsheet. The Bates number column indicates a Bates number Maxwell/her counsel identified as one she had an "images not exported" issue; the "Export File" column indicates what Relativity production export it was from; and the "Relativity Search Result" column indicates what the possible issue is with the Bates number identified. Descriptions of each type of entry in the spreadsheet are below. Let me know if you have any questions. Thanks, CORRUPTED DOC W/ EXTRACTED TEXT - This indicates that the original document was corrupt but we were able to supply extracted

The letter, written by defense attorney Bobbi C. Sternheim, responds to the MDC's justification for ...

The letter, written by defense attorney Bobbi C. Sternheim, responds to the MDC's justification for confiscating Ghislaine Maxwell's confidential legal documents, arguing that it was unjustified and violated Maxwell's 6th Amendment rights. The letter requests the court to deny the MDC's request and order relief, including summoning the responsible guards to court and providing a copy of the video recording to defense counsel. The MDC is accused of failing to provide a legitimate explanation for the violation.