From: Brian Bums ctl
Summary
From: Brian Bums ctl To: Nathan NYSD Chamber>, hcsternheim mac.com Cc: Mennin Jeff Pagliuca , Patrick Smith Subject: [EXTERNAL] RE: 20cr330, US v. Maxwell - Request for to ECF as "movant" Date: Thu, 18 Nov 2021 23:20:29 +0000 Attachments: 2021.11.18_-_Letter_from_Patrick J_Smith_to_Judge_Nathan_re_ECF.pdf , "Laura to be added Dear Judge Nathan — Attached please find a letter requesting that be added to ECF as a "movant" in this case so she may file papers on the docket as directed by the Court. We are available should the Court have any questions. Respectfully submitted, Brian T. Burns Smith Villazor LLP New York, New York 10019 Office I Direct From: Nathan NYSD Chambers Sent: Monday, November 15, 2021 8:36 PM To: bcsternheim_mac.com Cc: Brian Burns Mobile Menninger < >; Subject: [EXTERNAL EMAIL] Re: 20cr330, US v. Maxwell Counsel: Attached please find a corrected memo endorsement. Please disregard the prior email, and please confirm receipt. Sincerely,
Persons Referenced (4)
“...PM To: Nathan NYSD Chambers Cc: EFTA00090031 (USANYS) Jeff Pagliuca 4 '; Laura Menninger ; Patrick Smith Subject: Re: 20cr330, US v. Maxwell CAUTION - EXTERNAL: Rec...”
Defense Counsel“...call to Chambers this afternoon. We have copied counsel for the government and defense counsel on this email. We are available should the Court have any questions. Respectfu...”
United States“...D Chambers Cc: ; bcsternheim mac.com ; Patrick Smith EFTA00090032 Subject: United States v. Maxwell, 20 Cr. 330-AJN - Letter re Rule 17(c) Subpoena to CAUTION - EXTERN...”
Bobbi C. Sternheim“...ubject: Re: 20cr330, US v. Maxwell CAUTION - EXTERNAL: Received. Thank you. BOBBI C. STERNHEIM, ESQ. Law Offices of Bobbi C. Sternheim New York, NY 10007 Main: Cell: Fax...”
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EFTA DisclosureRelated Documents (6)
From: Nathan NYSD Chambers <
From: Nathan NYSD Chambers < To: bcsternheim mac.com Cc: Menninger" , Jeff Pagliuca Patrick Smith Subject: Re: 20cr330, US v. Maxwell Date: Tue, 16 Nov 2021 01:35:43 +0000 Attachments: 20cr330_ME_11.15.21.pdf , "Laura Counsel: Attached please find a corrected memo endorsement. Please disregard the prior email, and please confirm receipt. Sincerely, Chambers of the Hon. Alison J. Nathan From: BOBBI C STERNHEIM Sent: Monday, November 15, 2021 8:32 PM To: Nathan NYS0 Chambers Cc: (USANYS) C fl ; Jeff Pagliuca Laura Menninger ; Patrick Smith Subject: Re: 20cr330, US v. Maxwell CAUTION - EXTERNAL: Received. Thank you. BOBBI C. STERNHEIM, ESQ. Law Offices of Bobbi C. Sternheim New York, NY 10007 Main: Cell: Fax: .• • This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim EFTA00076149 that may be confidential and/or privileged. If you are not the intended recipient, you may not read, copy, distribute, or us
From: Nathan NYSD Chambers •
From: Nathan NYSD Chambers • To: Brian Burns Cc: to be added to ECF as Subject: Re: 20cr330, US v. Maxwell - Request for "movant" Date: Fri, 19 Nov 2021 14:45:50 +0000 Attachments: 20er330 ME 11.19.21.pdf Counsel: Attached please find a memo endorsement issued by Judge Nathan, which will be filed on the public docket. Sincerely, Chambers of the Hon. Alison J. Nathan From: Brian Burns Sent: Thursday, November 18, 2021 6:20 PM To: Nathan NYSD Chambers Cc Jeff Pagliuca <I >; Laura Menninger Patrick Smith Subject: RE: 20cr330, US v. Maxwell - Request for to be added to ECF as "movant" CAUTION - EXTERNAL: Dear Judge Nathan — Attached please find a letter requesting that be added to ECF as a "movant" in this case so she may file papers on the docket as directed by the Court. We are available should the Court have any questions. Respectfully submitted, Brian T. Burns Smith Villazor LLP New York, New York 10019 Office I Direct From: Nathan NYSD Chambers I Mobile
To: Laura Mennin er tennin e
From: To: Laura Mennin er tennin e mflaw.com>, " " • (USANYS)" Cc: Jeff Pagliuca [email protected]>, "Christian R Everdell - Cohen & Gresser LLP ([email protected])" <[email protected]>, 'BOBBI C STERNHEIM' <[email protected]> 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 Cc: Jeff Pagliuca It 'Bobbi Stemhet Subject: RE: US v. Maxwell - [conferral re photo and other discovery deficiencies] Date: Wed, 12 May 2021 03:15:02 +0000 Laura, I have consulted with the FBI and our vendor regarding the issues you raised with the overlay. Below is what I understand from them: • When using the overlay, you should require only a match of the hash value. • When our vendor uses the overlay, they do not see any production numbers that do not have a match in the index. If you are still seeing outliers, please let us know which files are not matching up with the index, and our vendor will look into what that issue could be. • The 17 files with no hash values were either incomplete files or corrupt files when they were recovered from the CDs. We produced them to you so that you would have a copy of every file on the CDs that did not have identifiable nudity. • Any non-unique hash values are duplicate files. There were many duplicat
From: '
From: ' " To: "M., (NY) (FBI)" <I Subject: FW: US v. Maxwell - [conferral re photo and other discovery deficiencies] Date: Tue, 31 Aug 2021 23:01:57 +0000 See below. Would you please make sure that the drives that were made available for Maxwell's counsel to review in the spring are preserved? If you could please send me an email confirming their preservation and where they will be stored, that would be great. Thanks, From: Laura Menninge Sent: Tuesday, August 31, 2021 6:30 PM To: Cc: >; Jeff Pagliuca (USANYS) [Contractor) (USANYS) Subject: RE: US v. Maxwell - [conferral re photo and other discovery deficiencies) Thank you for the follow up. Given that the FBI's records do not match mine, I would ask that you please preserve the two disks that I reviewed in New York in the event they are necessary for future litigation or production at trial. Best, Laura From: Sent: Tuesday, August 31 2021 3:23 PM To: Laura Menninger < Cc: Pagliuca [Contractor] •z: >; (USANYS
From: Laura Menninger <linenningerghinflaw.com>
From: Laura Menninger <linenningerghinflaw.com> To: ' USANYS)" Cc: Jeff Pagliuca <jpagliucaghinflaw.com>, '"ceverdellgcohengresser.comm e-ceverdel cohengresser.com>, "'Bobbi Sternheim ([email protected])"' <bcstemheiinginac.com> Subject: RE: US v. Maxwell - [conferral re photo and other discovery deficiencies) Date: Thu, 20 May 2021 19:27:58 +0000 lnline-Images: image001.png; image002.png Thank you for your explanation. I also have gone back to our IT department and, unfortunately, your FBI/vendor explanation is insufficient. • Based on our review, which has been double-checked, there are hash values in the overlay that don't match the index and visa- versa. • The snips below show an example of an entry from the overlay file you provided (with file names and MD5 Hash) which did not join to the non-nude index. We were able to find the corresponding file in the index using the file name, which in this particular instance was unique. As you can see, the MD5 hashes don't mat
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