To: Christian Everdell
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From: To: Christian Everdell Cc: "Laura Menninger" Jeff Pa liuca , "Bohhi Sternheim Subject: RE: US v. Maxwell - discovery production Date: Tue, 20 Oct 2020 13:49:25 +0000 Attachments: 2020.10.20_Maxwell Discovery_Letter.pdf Chris, Your drive is ready for pickup at the accompanying letter. Best, Assistant United States Attorney Southern District of New York From: Sent: Monday, October 19, 2020 5:47 PM To: Christian Everdell Cc: and Ms. Maxwell's drive has been sent to the MDC. Attached please find ; Mark S. Cohen ; Laura Menninger ; Jeff Pagliuca ; Bobbi Sternheim Subject: RE: US v. Maxwell - discovery production Chris, We have received the drives, thank you. They are being loaded, and I will let you know when yours is ready for pickup and when your client's has been sent to the MDC. I will have the agents plan for Friday from 8am to 3pm. Best, Assistant United States Attorney Southern District of New York From: Christian Everdell . Sent: Monday, Octobe
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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
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 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 3504-009 is a true and accurate copy of the transcript of a sworn statement taken on November 21, 2005 in West Palm Beach, Florida. EFTA00090929 2. IT IS FURTHER STIPULATED AND AGREED THAT this stipulation, marked as Government Exhibit 1005, and the document marked 3504-009, may be received in evidence as Government exhibits at trial subject to objections by the defense based on relevance, hearsay, or under
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
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
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
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