EFTA00018578

EFTA00021730

email: 1:20-cr-00330-PAE Document 135 Filed 05/04/21

Sophia Papapetru, Staff Attorney at the Federal Bureau of Prisons, emails Judge Nathan NYSD Chambers regarding the acceptance of an external hard drive from defense counsel in the US v Maxwell case. The MDC Brooklyn initially had restrictions on accepting external hard drives but has agreed to accept it from defense counsel without needing a court order. The MDC will coordinate with defense counsel for the delivery.

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

UNITED STATES DISTRICT COURT

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. x 20 Cr. 330 (AJN) MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF HER RENEWED MOTION FOR BAIL Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP New York, NY 10022 Phone: Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Denver, CO 80203 Phone: Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim New York, NY 10011 Phone: Attorneys for Ghislaine Maxwell EFTA00094289 TABLE OF CONTENTS Page PRELIMINARY STATEMENT 1 ARGUMENT 7 I. Reconsideration of the Court's Bail Decision is Appropriate Under 18 U.S.C. § 3142(O 7 II. Ms. Maxwell Should Be Granted Bail Under the Proposed Strict Bail Conditions 10 A. Ms. Maxwell Has Deep Family Ties to the United States and Numerous Sureties to Support Her Bond 10 1. Ms. Maxwell is Devoted to Her Spouse and Stepchildren and Would Never Destroy Her Family By Leaving th

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

EFTA00013225