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efta-efta00025278DOJ Data Set 8Correspondence

EFTA00025278

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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: ' Cc: )11 Subject: FW: [EXTERNAL] Re: Ghislaine Maxwell 02879-509 Date: Sun, 10 Oct 2021 23:17:45 +0000 Chiefs, FYI. From: BOBBI C STERNHEIM c Sent: Sunday, October 10, 2021 7:03 PM To: (BOP) < Cc: (BOP) ‹.. >; Christian Everdell < (USANYS) Subject: (EXTERNAL) Re: Ghislaine Maxwell 02879-509 >; Good evening- You failed to provide any update concerning the whereabouts of Ms. Maxwell's legal mail that I had placed in the legal mailbox on 10/2. However, on Friday afternoon, I was informed by Ms. Maxwell and Unit Manager that the envelope had been located and affixed to it was a bar-code type sticker, not generated by the MDC, but of the type issued by the U.S. Post Office. I had placed the envelope in the legal mailbox. It did not have postage. If, for some questionable reason, it had been handled by the U.S . Postal Service (which is highly unlikely and, if so, deliberately caused by the MDC), the Post Office would have returned it to my office address (at the return address on the envelope), not deliver it to the MDC without postage. This suggests some type of foul play on the part of the MDC, or at least some type of cover-up. I am informed that the Warden is aware of this. Today, I received the envelope from Unit Manager Today, Christian Everdell, Esq. and I had a scheduled legal visit with Ms. Maxwell. Rather than permitting us to use a somewhat larger room, we were required to use a room for two. This completely defeated the purpose of COVID protective measures. The plastic partition did not shield Mr. Everdell and there was little or no table surface for him to use. The room was unnecessarily cramped when a larger room was available. My request to use a larger room was denied. The officer claimed the team could not position the camera to focus on the larger room. This response was bogus. I requested to see the Warden, but that request was never honored. Further, defense counsel at large have heard about the current electricity issues affecting water, toilet flushing, and meals. Ms. Maxwell received a bologna sandwich despite being on no-flesh (vegetarian) diet. This is yet another blunder on the part of the MDC which needs to be immediately corrected. I will not waste my energy requesting a response because even if forthcoming it will likely be insufficient. These matters will be brought to the Court's attention, so you can start preparing excuses for consideration by Judge Nathan. Enjoy your holiday. Bobbi EFTA00025278 BOBBI C. STERNHEIM, ESQ. Law Offices of Bobbi C. Sternheim Main: Cell: Fax: This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim that may be confidential and/or privileged. If you are not the intended recipient, you may not read, copy, distribute, or use this information. If you have received this transmission in error, please notify the sender immediately by reply e-mail and then delete this message. Thank you. On Oct 7, 2021, at 7:45 AM, BOBBI C STERNHEIM c > wrote: Good morning- If by 9:30 this morning (10/7) Ms. Maxwell does not receive the legal mail deposited in the MDC legal mailbox on Saturday (10/2), an order to show cause will be filed with the Court. I urge you to respond and comply immediately. Bobbi BOBBI C. STERNHEIM, ESQ. Law Offices of Bobbi C. Sternheim Main: Cell: Fax: This message and any attached documents contain information from the Low Offices of Bobbi C. Sternheim that may be confidential and/or privileged. If you are not the intended recipient, you may not read, copy, distribute, or use this information. If you have received this transmission in error, please notify the sender immediately by reply e-mail and then delete this message. Thank you. On Oct 6, 2021, at 7:00 PM, BOBBI C STERNHEIM c wrote: Good afternoon- Ms. Maxwell still has not received the legal mail (a properly addressed manila envelope) that I deposited in the East Building legal mailbox on Saturday 10/2 shortly after 3 pm while I was escorted to the lobby by a male guard. Please contact me immediately. EFTA00025279 Thank you- Bobbi Please note my new office address and preferred email address: BOBBI C. STERNHEIM, ESQ. Law Offices of Bobbi C. Sternheim Main: Cell: Fax: This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim that may be confidential and/or privileged. If you are not the intended recipient, you may not read, copy, distribute, or use this information. If you have received this transmission in error, please notify the sender immediately by reply e-mail and then delete this message. Thank you. On Oct 6, 2021, at 4:53 AM, > wrote: I will follow up with the appropriate departments. BOBBI C STERNHEIM 10/5/2021 7:12 PM >>> Good evening- As of this writing, Ms. Maxwell has not received legal mail which I personally placed in the East Building legal mailbox on Saturday, October 2. On that same day, in that same mailbox, I deposited legal mail for a client housed in the west building. That client confirmed that he received his legal mail. Ms. Maxwell has not. Please explain why delivery of Ms. Maxwell's mail has been delayed. Time is of the essence. Her trial begins on November 29th. Every delay caused by the MDC interferes with her ability to prepare for trial. Your prompt response is requested. Thank you- Bobbi BOBBI C. STERNHEIM, ESQ. Law Offices of Bobbi C. Sternheim EFTA00025280 Main: Cell: Fax: This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim that may be confidential and/or privileged. If you are not the intended recipient, you may not read, copy, distribute, or use this information. If you have received this transmission in error, please notify the sender immediately by reply e-mail and then delete this message. Thank you. EFTA00025281

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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.

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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

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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

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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.

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