From: Christian Everdell
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From: Christian Everdell To: ' Cc: USANYS , Jeff Pagliuca 1pagliuca&mflaw.com>, "Laura Menninger" <[email protected]>, "[email protected]" <[email protected]> Subject: [EXTERNAL] RE: Redactions to MILs Date: Wed, 03 Nov 2021 05:27:10 +0000 Attachments: Verdict_Sheet_Govt_Proposed_Defense_Redlines_[2021.10.29].DOCX Attached is the redlined version of the verdict sheet. Thanks, Chris From: Christian Everdell Sent: Wednesday, November 3, 2021 12:19 AM To: 11 )1 Cc: (USANYS) Jeff Pagliuca <[email protected]>; Laura Menninger <[email protected]>; [email protected] Subject: RE: Redactions to MILs >; Attached is the full redline of the RTCs. I made some changes to the sections I already sent you. Those are highlighted in yellow. I will send you the verdict sheet later tonight. Regarding the "Minor-Victim" terminology, I know the redactions are a pain, but it is still our position that there is no need to anonymize them and we object to calling them both
Persons Referenced (3)
“...a.m. so we have some time before this is due to the Court. Thanks, Assistant United States Attorney Southern District of New York 1 Saint Andrews Plaza New York, New Y...”
United States Attorney“...a.m. so we have some time before this is due to the Court. Thanks, Assistant United States Attorney Southern District of New York 1 Saint Andrews Plaza New York, New York 10007...”
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EFTA DisclosureRelated Documents (6)
From: '
From: ' To:I Cc: ' " Subject: RE: FW: Letter Date: Tue, 22 Sep 2020 15:23:55 +0000 Inline-Images: image001.png; image002jpg )11 < (USANYS)" Thanks so much. Would 2pm work? Best From: Sent: Tuesday, September 22, 2020 11:22 AM To: Cc: Subject: Re: FW: Letter H Sure. What time works for you? Bes >>> Hi (USANYS)ca > 9/22/2020 11:15 AM >> > Please see the attached letter from Maxwell's counsel. Would you be available for a call to discuss this afternoon, please? Thanks, Assistant United States Attorney Southern District of New York 1 St. Andrew's Plaza New York, NY 10007 From: Christian Everdell . Sent: Monday, September 21, 2020 10:33 PM To: ) <->% (USANYS) Cc: Mark S. Cohen c Laura Menninger cMa Jeff Pagliuca EFTA00097194 Subject: Letter Please see the attached letter regarding Ghislaine Maxwell. Thank you in advance for your attention to these matters. Regards, Chris Christian Everdell COHEN & GRESSER LLP 800 Third Avenue New York NY 1002, wor
UNITED STATES DISTRICT COURT
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA STIPULATION GHISLAINE MAXWELL, Defendant. x S2 20 CR 330 (AJN) IT IS HEREBY STIPULATED AND AGREED by and among the United States of America, by Damian Williams. United States Attorney for the Southern District of New York, and and Assistant United States Attorneys, of counsel, and defendant Ghislaine Maxwell, by and with the consent of her attorneys, Christopher Everdell, Esq., Laura Menninger, Esq., Jeffrey Pagliuca, Esq., and Bobbi Sternheim, Esq., that: 1. The document marked 3506-001 is a true and accurate copy of a transcript of the deposition taken on November 6, 2009 in West Palm Beach, Florida. EFTA00099019 2. IT IS FURTHER STIPULATED AND AGREED THAT this stipulation, marked as Government Exhibit 1006 may be received in evidence at trial. Dated: November 2021 New York, New York DAMIAN WILLIAMS United States Attorney for the Southern District of New York By: Ass
"Laura Menninger"
"Laura Menninger" , Jeff Pagliuc , " SANYS " Subject: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Date: Thu, 06 May 2021 23:15:43 +0000 Counsel, We write to confer in accordance with the Court's Order about a trial date in this case. Please let us know your preferences and availability for trial dates from September 2021 through the end of the year. If you could please provide details for any conflicts, that would be helpful. Thank you, Assistant United States Attorney Southern District of New York One Saint Andrew's Plaza New York. NY 10007 EFTA00085169
(USANYS)"
From: (USANYS)" To: "MMINar m ir>, (USANYS)" Cc: "I ).:E= M> > " (USANYS)" Subject: RE: Redactions to MILs Date: Wed, 03 Nov 2021 19:56:03 +0000 Attachments: Jury_Instructions_Govt_Proposed_Defense_Redlines_2021.11.01_v2_AR_(002)- TAM.docx Here are my comments on the rest. I'll come by to discuss the few items in a few. From: Sent: Wednesday, November 3, 2021 1:40 PM To: (USANYS) Cc: ) (USANYS) Subject: RE: Redactions to MILs >; > USANYS) >; Thanks, ! Here's the rest of the RTC. I've also attached their proposed verdict form, though the only edits there seem to follow from their proposed edits to the instructions on Counts Two and Four. Wherever we land on that, I'll include a global objection (or accept the edits) to the verdict form. You've reviewed everything before the aiding/abetting instruction (p. 45 of the PDF, p. 42 of the document), but it's worth scrolling through the first bit, because the defense added some things in highlighting when they se
To: Jeff Pagliuca
From: " To: Jeff Pagliuca Cc: Sabina Mariella "Si McCawley Laura Mennin er Subject: RE: Documents Per Judge Nathan's Order Date: Thu, 22 Apr 2021 01:20:49 +0000 Attachments: Ex._B_2021.04.05_BSF_Reply_re_Maxwell_Rule_17(c)_Subpoena_- _Prpsd_Redact.._[Govemment_Proposed_Redactions].pdf; 2021.04.05 JEISF_Reply_re_Maxwell_Rule_17(c)_Subpoent[Govemment_Proposed_Reda ctions].pdf; 2021.04.19_LAM_Joint_Letter_with_BSF_re_redactiontin_Rule_17_pleadingsiGovemm ent_Proposed_Redactions].pdf; 2021.04.02_Defts_Resp_to_BSF_Ltr._Motn_to_Quash_Rule_17_SubiGovernment_Propos ed Redactions].pdf; Ex. A_2021.04.02_Defts_Resp_to_BSF_Ltr._Motn_to_Quash_Rule_17_Sub_- Prp;c1.._[Govemment_Proposed_Redactions].pdf Good evening, Our team has reviewed the documents and intends to propose a limited number of redactions to protect third party privacy interests. Attached please find pdfs with our proposed redactions in red boxes. Would you please let me know your respective positions regarding th
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
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