EFTA00028849

From: Christian Everdell

From: Christian Everdell Cc: "Mark S. Cohen" To: a" lYin>, " (USANYS)" (USANYS)" < Bobbi Stcrnheim Jeff Pagliuca , "'Laura Menninger"' Subject: Discovery Requests Date: Thu, 07 Jan 2021 21:13:14 +0000 Attachments: 2020.11.18_Maxwell_Discovery_Letter.pdf; 2006.12.06_FBI_Report.pdf; PROD011- Ciaps.xlsx Inline-Images: image005.jpg; image006.jpg We write to raise a number of discovery issues. Please let us know your position on these issues at your earliest convenience. 1. In our email correspondence on 11/18/2020, you agreed to create a new hard drive containing the entire discovery production. We provided you with a 4TB hard drive for that purpose on 11/20/2020. It is very important for Ms. Maxwell to have this drive as soon as possible to prepare her defense. Do you have an update on when the drive will be ready? 2. We also informed you that the CD produced on November 18, 2020 did not work on the prison computer at the MDC (as you know, the laptop provided to Ms. Max

Court Filing: 123

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.

EFTA00019897

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.

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.

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