To: Laura Menninger
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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
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From: " To: ' " < > ,' (USANYS)" Subject: FW: US v. Maxwell - 20 Cr. 330 (MN) - Request to view evidence, highly confidential materials, scenes Date: Tue, 09 Mar 2021 20:56:56 +0000 Inline-Images: image00 1 jpg Proposed response below. Good with you? To my knowledge, that is the only excel spreadsheet in our possession that indexes physical evidence related to this case. The discovery productions also included search warrant returns listing the physical items seized by the FBI's New York Office during the 2019 searches of Jeffrey Epstein's residences in New York and the U.S Virgin Islands, but they are not contained in a spreadsheet. As a courtesy, I have asked the FBI whether it would be possible to provide us with a similar excel index reflecting the physical evidence seized by the FBI's New York Office, though it may take some time to complete such an index. Best, From: Laura Menninger <Imenninger@hmflaw.com> Sent: Tuesday, March 9, 2021 3:44 PM To: ) )< ›; (
To: Laura Mennin er
From: To: Laura Mennin er Christian Everdell Cc: Jeff Pa , "Bobbi Stemheim ( a)" (USANYS) [Contractor]" (USANYS) [Contractor]" USANYS) [Contractor 6 a> Subject: RE: Discovery Issues Date: Fri, 21 May 2021 02:45:33 +0000 Attachments: 2021.05.20_Maxwell_Discovery_Letter.pdf; 2021.05.20_Supplementary_Production_Notes_for_Defense_Counsel.xlsx Inline-Images: image001.jpg; image002.jpg Counsel, Today we have an additional discovery production ready to send to you. This production is small enough to produce via USAfx. Please let us know if you do not already have a USAfx account, in which case our paralegals (cc'd) can assist you in creating an account. We are also sending a CD containing this production to the MDC via FedEx. Attached please find a cover letter accompanying this production. As you will see in the letter, the majority of this production consists of materials we are providing in response to your requests for additional information regarding the SUPP production
From: '
From: ' y. „cl [Contractor]" (USANYSCo ntractor " (USANYS) [Contractor To: ' Cc: ' (USANYS ) [Contractorr <W " ) (USANYS)" Subject: RE: Discovery Issues Date: Wed, 12 May 2021 13:54:21 +0000 Great, thanks very much. Let's say 11am? From: (USANYS) [Contractor] < Sent: Wednesday, May 12, 2021 9:43 AM To: (USANYS) [Contractor] Cc: Subject: Re: Discovery Issues As am I. On May 12, 2021, at 9:36 AM, From: Sent: Tuesday, May 11, 2021 10:41 PM To: (USANYS) [Contractor] < (USANYS) [Contractor] (USANYS) [Contractor] < M> Cc: (USANYS)<a Subject: FW: Discovery Issues and I are both available anytime today. (USANYS) [Contractor) (USANYS) (USANYS) [Contractor] < wrote: Hi team, Maxwell's attorneys have asked for the below-listed information from the SUPP production that went out on November 9, 2021. Is there a time tomorrow when we can have a call to discuss, please? Thanks, From: Laura Menninger Sent: Friday, May 7, 20214:53 PM To: >; Christian Everdell
(USANYS) [Contractor]" <
From: (USANYS) [Contractor]" < To: Cc: ' (USANYSContract , (USANYS) [Contractor]" Subject: RE: Discovery Issues Date: Fri, 21 May 2021 17:00:25 +0000 Inline-Images: iinage001.jpg; image002.jpg USANYS)" Great, the disc and password under separate cover have been left for FedEx. From: Sent: Friday, May 21, 2021 12:33 PM To: (USANYS) [Contractor] Cc: (USANYS) (USANYS) [Contractor] c > (USANYS) [Contractor] Subject: RE: Discovery Issues Letters look good, thanks! This is good to go out. From: (USANYS) [Contractor] .‘z . Sent: Friday, May 21, 2021 12:14 PM To: ) Cc: (USANYS) [Contractor] Subject: RE: Discovery Issues <M > (USANYS) (USANYS) [Contractor] Disc is burned and ready to get sent out to MDC. Draft cover letters are attached and saved here. Please let me know if you have any revisions. Thanks, From: Sent: Thursday, May 20, 2021 10:46 PM To: Laura Menninger (: ); Christian Everdell (USANYS) Cc: Jeff Pagliuca Bobbi Sternheim (USANYS) [Contractor
To: Laura Mennin er tennin e
From: To: Laura Mennin er tennin e mflaw.com>, " " • (USANYS)" Cc: Jeff Pagliuca ipagliuca@hmflaw.com>, "Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)" <ceverdell@cohengresser.com>, 'BOBBI C STERNHEIM' <bcstemheim@mac.com> 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
To: Laura Mennin er
From: To: Laura Mennin er , " " (USANYS)" Cc: Jeff Pagliuca "Christian R Everdell - Cohen & Gresser LLP (ceverdell a cohen sser.com)" 'BOBBI C STERNHEIM' Subject: RE: US v. Maxwell - 20 Cr. 330 (MN) - Request to view evidence, highly confidential materials, scenes Date: Wed, 07 Apr 2021 04:09:12 +0000 Attachments: New_York Evidence List_- Annotated by_AUSA.xlsx; Florida Evidence List_- Annotatect by_AUS—A.xlsx;—Florida_Evidence_Sub-Item_List_- _—AnnotatecT by_AUSA.xlsx Inline-Images: image00 1 jpg Good evening, Today, the Marshals confirmed that they will produce Ms. Maxwell to 500 Pearl Street on April 13, 2021 and every day thereafter until the evidence review is complete. My understanding is that Ms. Maxwell should arrive to 500 Pearl Street at approximately 9:30am each morning. So we are confirmed for evidence review in the proffer rooms on the 5th floor of the 500 Pearl Street courthouse beginning at 9:30am on April 13th. I will plan to be present and to contin
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