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efta-efta00039872DOJ Data Set 9Other

Subject: RE: FW: Ghislaine Maxwell 02879-509

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Unknown
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DOJ Data Set 9
Reference
EFTA 00039872
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3
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4
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From: To: Cc: Subject: RE: FW: Ghislaine Maxwell 02879-509 Date: Mon, 16 Nov 2020 17:35:53 +0000 I'll be available at my desk for the next hour, but I'll be on back-to-back calls from 1:30pm to 6pm. Would you be able to please call me before 1:30 today? From: Sent: Monday, November 16, 2020 10:37 AM To Cc Su ject: RE: FW: Ghislaine Maxwell 02879-50 No problem, thanks very much. I'm at my desk From Sent: Monday, November 16, 2020 10:35 AM To Cc Subject: Re: FW: Ghislaine Maxwell 02879-509 Yes, sorry it has been crazy. Give me a a few minutes. what number? >>> 11/16/2020 10:29 AM >» Hi Are you available for a call today to discuss Maxwell? In addition to Bobbi's email, I'd like to discuss the logistics of delivering a laptop for Maxwell to use when reviewing her discovery. Thanks, Assistant United States Attorney Southern District of New York 1 St. Andrew's Plaza New York NY 10007 From: BOBBI C STERNHEIM • Sent: Monday, November 16, 2020 9:50 AM To: BRO-Ex

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From: To: Cc: Subject: RE: FW: Ghislaine Maxwell 02879-509 Date: Mon, 16 Nov 2020 17:35:53 +0000 I'll be available at my desk for the next hour, but I'll be on back-to-back calls from 1:30pm to 6pm. Would you be able to please call me before 1:30 today? From: Sent: Monday, November 16, 2020 10:37 AM To Cc Su ject: RE: FW: Ghislaine Maxwell 02879-50 No problem, thanks very much. I'm at my desk From Sent: Monday, November 16, 2020 10:35 AM To Cc Subject: Re: FW: Ghislaine Maxwell 02879-509 Yes, sorry it has been crazy. Give me a a few minutes. what number? >>> 11/16/2020 10:29 AM >» Hi Are you available for a call today to discuss Maxwell? In addition to Bobbi's email, I'd like to discuss the logistics of delivering a laptop for Maxwell to use when reviewing her discovery. Thanks, Assistant United States Attorney Southern District of New York 1 St. Andrew's Plaza New York NY 10007 From: BOBBI C STERNHEIM • Sent: Monday, November 16, 2020 9:50 AM To: BRO-ExecAssistant-S Cc Subject: Ghislaine Maxwell 02879-509 Good afternoon- I am informed that the NYC Dept. of Design & Construction will shut off water and heat to the MDC from 9:00 pm to 5:00 am beginning tonight until 11/21. I am further informed that the MDC will give inmates one bottle of water and an extra blanket due to this disruption of services. I am requesting that my client - Ghislaine Maxwell (02879-509) be moved from her present isolation cell with two exterior walls to an interior cell. Please explain why she cannot be moved to the cell in the dayroom area where, by Court order, she is permitted to review discovery EFTA00039872 from 7:00 am to 8:00 pm. Thank you- Bobbi C. Sternheim BOBBI C. STERNHEIM, ESQ. Law Offices of Bobbi C. Stemheim 33 West 19th Street - 4th Floor New York, NY 10011 ••Covid-19 Notice: The \Vest 19th Street office is currently closed but we continue to work remotely. Please use entail or fax, instead of regular mail, for all correspondence during this time. We continue to work regular business hours throughout this situation. Thank you for your consideration. Our best wishes for your good health and well being. This message and any attached documents contain information from the Law Offices of Bobbi C. Stemheim 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 Nov 10, 2020, at 1:45 PM, BRO-ExecAssistant-S wrote: The City contacted us and they said the water and heat will not be shut off. The information has been posted on the inmate Bulletin. >>> BOBBI C STERNHEIM Good afternoon- I am informed that the NYC Dept. of Design & Construction will shut off water and heat to the MDC from 8:30 pm to 4:00 am beginning tonight until 11/17. I am further informed that the MDC will give inmates a bottle of water and an extra blanket due to this disruption of services. I am requesting that my client - Ghislaine Maxwell (02879-509) be moved from her present isolation cell with two exterior walls to an interior cell. Please explain why she cannot be moved to the cell in the dayroom area where, by Court order, she is permitted to review discovery from 7:00 am to 8:00 pm. Thank you- Bobbi C. Sternheim BOBBI C. STERNHEIM, ESQ. Law Offices of Bobbi C. Stemheim 33 West 19th Street - 4th Floor New York, NY 10011 1/9/2020 3:47 PM >>> ••Covid-19 Notice: The West 19th Street office is currently closed but we continue to work remotely. Please use email or fax, instead of regular mail, for all correspondence during this time. We continue to work regular business hours throughout this situation. Thank you for your consideration. Our best wishes for your good health and well being. EFTA00039873 This message and any attached documents contain information from the Law Offices of Bobbi C. Stemheim 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. EFTA00039874

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U.S. Department of Justice United States Attorney Southern District of New York The Silvio I. Motto Building One Saint Andrew's Plaza New York. New York 10007 October 20, 2020 BY ELECTRONIC MAIL Christian Everdell, Esq. Mark Cohen, Esq. Cohen & Gresser LLP 800 Third Avenue New York, NY 10022 Laura Menninger, Esq. Jeffrey Pagliuca, Esq. Haddon, Morgan and Foreman, P.C. 150 East Tenth Avenue Denver, CO 80203 Bobbi Sternheim, Esq. Law Offices of Bobbi C. Sternheim 33 West 19th Street-4th Fl. New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Counsel: In recognition of the Government's ongoing discovery obligations, today we are producing copies of the materials listed in the below index, which materials are stamped with control numbers SDNY_GM_00328070 through SDNY_GM_00356148. The password for the drive is "USAOsdnyl!". The materials are available for pickup at the U.S. Attorney's Office in Manhattan. Please note that both this l

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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA v. GHISLAINE MAXWELL, Defendant. x S2 20 Cr. 330 (AJN) MS. MAXWELL'S MOTION FOR AN ORDER AUTHORIZING A SUBPOENA PURSUANT TO FED. R. CRIM. P 17(c)(3) Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver CO 80203 Phone: Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York NY 10022 Phone: Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim 225 Broadway, Suite 715 New York NY 10007 Phone: Attorneys for Chislaine Maxwell EFTA00105542 Defendant Ghislaine Maxwell requests that the Court enter an Order authorizing her counsel to issue a subpoena under Federal Rule of Criminal Procedure 17(c) to Epstein Victim's Compensation Program, for certain items identified in Attachment A to the proposed Subpoena, together attached as Exhibit 1 to this Motion, for the following reasons: I. Background On October 11, 2021, the gove

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120 LBUCmaxl UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. Before: 20 CR 330 (AJN) Jury Trial New York, N.Y. November 30, 2021 8:50 a.m. HON. ALISON J. NATHAN, APPEARANCES DAMIAN United States Attorney for the Southern District of New York BY: Assistant United States Attorneys HADDON MORGAN AND FOREMAN Attorneys for Defendant BY: JEFFREY S. PAGLIUCA CHRISTIAN R. EVERDELL LAURA A. MENNINGER -and- BOBBI C. STERNHEIM -and- RENATO STABILE Also Present: District Judge , FBI NYPD Sunny Drescher, Paralegal, U.S. Attorney's Office Ann Lundberg, Paralegal, Haddon Morgan and Foreman SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068582 121 LBUCmaxl 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 (Jury not present) THE COURT: Looks like we have everybody. Matt

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From: '

From: ' y• < To: BOBBI Cc:' Subject: RE: Ghislaine Maxwell 02879-509 Date: Mon, 16 Nov 2020 18:06:58 +0000 (USANYS)" Bobbi, Thank you for including me on this email. I understand from my conversation with MDC legal counsel today that MDC staff is continuing to monitor temperatures throughout the facility, including in the area where Ms. Maxwell is housed. My understanding is that the temperature where Ms. Maxwell is housed remains within the limits prescribed by BOP policy and that the MDC does not expect this week's activities to affect the temperature in Ms. Maxwell's cell. That said, they will continue to monitor the temperature and take appropriate action if it falls below prescribed limits. As has previously been conveyed via letter from the Government to defense counsel dated October 8, 2020, the MDC's assessment continues to be that Ms. Maxwell's current cell is the most appropriate placement for Ms. Maxwell both for her safety and the security of the institution.

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7.7 LBTCMAXVD1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. Before: 20 CR 330 (AJN) Jury Trial New York, N.Y. November 29, 2021 10:30 a.m. HON. ALISON J. NATHAN, APPEARANCES DAMIAN WILLIAMS United States Attorney for the Southern District of New York BY: Assistant United States Attorneys HADDON MORGAN AND FOREMAN Attorneys for Defendant BY: JEFFREY S. PAGLIUCA CHRISTIAN R. EVERDELL LAURA A. MENNINGER -and- BOBBI C. STERNHEIM -and- RENATO STABILE Also Present: District Judge Paralegal, U.S. Attorney's Office Ann Lundberg, Paralegal, Haddon Morgan and Foreman SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00085001 721 LBTCMAXVD1 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 (In open court) (Voir dire resumed) THE COURT: I have an update. So the one jur

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