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efta-efta00080617DOJ Data Set 9Other

From: Christian Everdell

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DOJ Data Set 9
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EFTA 00080617
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From: Christian Everdell To: " " (USANYS)" Cc: Bobbi Stemheirn Subject: Discovery Laptop Access Date: Wed, 13 Jan 2021 06:05:35 +0000 Embedded: Discovery_Requests.msg Inline-Images: image001.jpg; image002.jpg I write to again request that Ms. Maxwell be given access to the laptop computer on the weekends. She recently informed us that the prison computer can't read a substantial portion of the materials on the hard drives. This means that she effectively loses the entire weekend to review her discovery. If she was able to have access to the laptop on the weekends when she was in quarantine, I don't see why she cannot have it now. Also, Ms. Maxwell still has not received the 4TB hard drive with the complete production or the smaller hard drive with the materials that were originally produced on the CD. Can you please let me know when they will be provided to her? Finally, we renew our discovery requests set forth in our 1/7/2021 email (see attached). In particular, we would

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From: Christian Everdell To: " " (USANYS)" Cc: Bobbi Stemheirn Subject: Discovery Laptop Access Date: Wed, 13 Jan 2021 06:05:35 +0000 Embedded: Discovery_Requests.msg Inline-Images: image001.jpg; image002.jpg I write to again request that Ms. Maxwell be given access to the laptop computer on the weekends. She recently informed us that the prison computer can't read a substantial portion of the materials on the hard drives. This means that she effectively loses the entire weekend to review her discovery. If she was able to have access to the laptop on the weekends when she was in quarantine, I don't see why she cannot have it now. Also, Ms. Maxwell still has not received the 4TB hard drive with the complete production or the smaller hard drive with the materials that were originally produced on the CD. Can you please let me know when they will be provided to her? Finally, we renew our discovery requests set forth in our 1/7/2021 email (see attached). In particular, we would like to receive as soon as possible the list of Subject Devices in request #3. When can we expect to receive that? Regards, Chris Christian R Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 www.cohengresser.com New York I Paris I Washington DC I London I view bio CONFIDENTIALITY NOTICE: The information contained in this e-mail may be confidential and/or privileged. This e-mail is intended to be reviewed initially by only the individual named above. II the reader of this e-mail is not the intended recipient or a representative of the intended recipient. you are hereby notified that any review. dissemination or copying of this e-mail or the information contained herein is prohibited. If you have received this e-mail in error. please immediately notify the sender by telephone and permanently delete this e-mail. Thank you. PRIVACY: A complete copy of our privacy policy can be viewed al: MoslAvww.cohenoresser.com/privacwolicx EFTA00080617

Related Documents (6)

DOJ Data Set 8CorrespondenceUnknown

EFTA00019897

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Court UnsealedLegal FilingUnknown

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.

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House OversightLegal FilingUnknown

Defense attorney Christian R. Everdell requests that the court order the MDC to accept two hard driv...

Defense attorney Christian R. Everdell requests that the court order the MDC to accept two hard drives containing non-Highly Confidential discovery materials for Ghislaine Maxwell's use. The hard drives are organized in a user-friendly format, and the government does not object to the request. The MDC Legal Department has expressed concerns and is given the opportunity to note objections.

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Court UnsealedLegal FilingUnknown

Declaration in Support of Motion to Withdraw as Co-Counsel: 798-1

Christian R. Everdell of Cohen & Gresser LLP declares that the firm is withdrawing as co-counsel for Ghislaine Maxwell with her consent, as Markus Moss PLLC has taken over her representation for the government's motion to unseal grand jury transcripts. Cohen & Gresser LLP represented Maxwell during her trial and sentencing but not in her appellate proceedings. The firm will share its files with Markus Moss PLLC upon request.

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Court UnsealedCorrespondenceUnknown

Court Filing - Letter to Judge: Case1:20-cr-03320-AJN Document 292 Filed 08/27/20 Page 20 of 1164

The defense attorneys for Ghislaine Maxwell request a protective order from Judge Alison J. Nathan to govern the handling of discovery materials. The parties have reached agreement on most provisions but remain at odds over restrictions on government witnesses and the disclosure of alleged victim identities.

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Court UnsealedLegal FilingUnknown

Court filings: 8

The documents include court filings related to the cases of Ghislaine Maxwell and Jeffrey Epstein. The first filing concerns the scheduling of Maxwell's arraignment and bail hearing, while the second is related to Epstein's bail motion and financial disclosure.

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