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efta-efta00095491DOJ Data Set 9Other

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DOJ Data Set 9
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EFTA 00095491
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From: ' To: (USANYS) [Contractor]" Cc: al >, )II Subject: RE: Joint Letter re: Redactions to MILs Date: Fri, 29 Oct 2021 18:28:24 +0000 Attachments: 2021.10.29 MDC - Maxwell MAIN.docx; 2021.10.29 MDC - Maxwell PASSWORD.docx Inline-Images: image001.gif; image002.jpg I've loaded the drive and it should be ready to go out (if you'd like to look at it just let me know, otherwise I think it's good to go out). Cover letters attached for your review, and we can send it via FedEx this afternoon. From: (USANYS) Sent: Friday, October 29, 2021 2:14 PM To: Cc: Subject: RE: Joint Letter re: Redactions to MILs This looks right. If you want me to take a look at anything, I can stop by. From: Sent: Friday, October 29, 2021 1:44 PM To: (USANYS) Cc: Subject: RE: Joint Letter re: Redactions to MILs (USANYS) [Contractor) (USANYS) [Contractor] I've received the drive and am confirming that the following should be loaded onto it: • 10/13 discovery production (spreadsheets) • 10/

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From: ' To: (USANYS) [Contractor]" Cc: al >, )II Subject: RE: Joint Letter re: Redactions to MILs Date: Fri, 29 Oct 2021 18:28:24 +0000 Attachments: 2021.10.29 MDC - Maxwell MAIN.docx; 2021.10.29 MDC - Maxwell PASSWORD.docx Inline-Images: image001.gif; image002.jpg I've loaded the drive and it should be ready to go out (if you'd like to look at it just let me know, otherwise I think it's good to go out). Cover letters attached for your review, and we can send it via FedEx this afternoon. From: (USANYS) Sent: Friday, October 29, 2021 2:14 PM To: Cc: Subject: RE: Joint Letter re: Redactions to MILs This looks right. If you want me to take a look at anything, I can stop by. From: Sent: Friday, October 29, 2021 1:44 PM To: (USANYS) Cc: Subject: RE: Joint Letter re: Redactions to MILs (USANYS) [Contractor) (USANYS) [Contractor] I've received the drive and am confirming that the following should be loaded onto it: • 10/13 discovery production (spreadsheets) • 10/25 3500 production (contains TW and NTW productions and updated indices) • 10/25 discovery production (AIC, AT&T, VR birth certificate) • 10/28 GX production (GXs 14, 16, 416-B and updated index) • 10/28 discovery production (various materials produced last night) From: (USANYS) Sent: Friday, October 29, 2021 12:50 PM To: Cc: Subject: FW: Joint Letter re: Redactions to MILs (USANYS) [contractor] Hi — See below. Can you please keep an eye out for the hard drive and then load it with the below. Happy to walk through what should be on the drive. Let us know if you have any questions. Thanks! From: Christian Everdell Sent: Friday, October 29, 2021 12:48 PM EFTA00095491 To: (USANYS) < >; Cc: >; Jeff Pagliuca • Thomas J. Powers Subject: [EXTERNAL] RE: Joint Letter re: Redactions to MILs Laura Menninger Thanks, M. I will send you our proposed redactions shortly. And I will send you text for the joint letter a little later. Also, we are delivering to you today (attn: a 1TB encrypted hard drive. Please load it with all of the productions since the 10/11 production and send it to Ms. Maxwell at MDC as soon as possible. That should be the 10/13, 10/25, and 10/28 productions. Please do not use McAfee encryption software to encrypt the data on the drives. That causes enormous problems for us. The drive will have external encryption, so there is no need for the McAfee encryption. Thanks, Chris From: (USANYS) Sent: Friday, October 29, 2021 11:51 AM To: Christian Everdell Cc: Jeff Pagliuca Laura Menninger Subject: RE: Joint Letter re: Redactions to MILs Thanks, Chris. We intend to send you our proposed redactions to your motions soon. You can then add any proposed redactions to your motions on top of what we send to you. Can you please send us your proposed redactions to our motions, as well as language for us to include in a joint letter about your proposed redactions? Thanks, From: Christian Everdell < Sent: Friday, October 29, 2021 11:35 AM To: >; Cc: Subject: (EXTERNAL] Joint Letter re: Redactions to MILs (USANYS) < >; Jeff Pagliuca < ; Laura Menninger As I'm sure you know, the Court has ordered the parties to file a joint letter proposing redactions to the MILs by the end of today. We have a few proposed redactions. How do you propose we handle this? Thanks, Chris Christian R Everdell EFTA00095492 COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 view bio www.cohengresser.com New York I Paris I Washington DC I London CONFIDENTIALITY NOTICE: The information contained in this e-mail may be confidential and/or ptivileged. This e-mail is intended to be reviewed initially by only the individual named above. If 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 enrol, 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 at https:/Avww.cohenctressercom/privacK-policx EFTA00095493

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DOJ Data Set 9OtherUnknown

From: Christian Everdell

From: Christian Everdell Cc: "Mark S. Cohen" To: a" lYin>, " (USANYS)" (USANYS)" < Bobbi Stcrnheim Jeff Pagliuca , "'Laura Menninger"' Subject: Discovery Requests Date: Thu, 07 Jan 2021 21:13:14 +0000 Attachments: 2020.11.18_Maxwell_Discovery_Letter.pdf; 2006.12.06_FBI_Report.pdf; PROD011- Ciaps.xlsx Inline-Images: image005.jpg; image006.jpg We write to raise a number of discovery issues. Please let us know your position on these issues at your earliest convenience. 1. In our email correspondence on 11/18/2020, you agreed to create a new hard drive containing the entire discovery production. We provided you with a 4TB hard drive for that purpose on 11/20/2020. It is very important for Ms. Maxwell to have this drive as soon as possible to prepare her defense. Do you have an update on when the drive will be ready? 2. We also informed you that the CD produced on November 18, 2020 did not work on the prison computer at the MDC (as you know, the laptop provided to Ms. Max

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DOJ Data Set 8CorrespondenceUnknown

EFTA00019897

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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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The document is a notice of electronic filing from the US District Court, Southern District of New York, indicating that the appeal record in USA v. Maxwell has been transmitted to the US Court of Appeals. It includes details about the case, the charges against Ghislaine Maxwell, and the attorneys involved. The case involves charges of conspiracy, enticement, and transportation of minors for illegal sex acts, among others.

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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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