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DOJ Data Set 9
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EFTA 00098331
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From: " (USANYS) [Contractor]" To: "MM.=)r>, [Contractor]" (USANYS) Cc: " ) e"<SIMpla(USANYS)" Subject: RE: US v. Maxwell - discovery production Date: Thu, 12 Aug 2021 19:45:29 +0000 Attachments: 2021.08.12_MDC_-_Maxwell_MAIN.pdf; 2021.08.12_MDC_-_Maxwell_PASSWORD.pdf The drive is ready to be sent to MDC. The cover letters are attached; if they look good to go, we can leave the drive for FedEx pickup. Thanks so much! From: Sent: Thursday, August 12, 2021 2:26 PM To: (USANYS) [Contractor] < Cc: C ; (USANYS) < 1< Subject: RE: US v. Maxwell - discovery production Great, thank you so much! (USANYS) [Contractor] From: (USANYS) [Contractor] Sent: Thursday, August 12, 2021 2:19 PM To: (USANYS) [Contractor] Cc: < )'; (USANYS) S Subject: RE: US v. Maxwell - discovery production We'll work on loading the files to their drive this afternoon; it shouldn't take long. If helpful, below are our explanations for how to open certain file types or explanations for why

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From: " (USANYS) [Contractor]" To: "MM.=)r>, [Contractor]" (USANYS) Cc: " ) e"<SIMpla(USANYS)" Subject: RE: US v. Maxwell - discovery production Date: Thu, 12 Aug 2021 19:45:29 +0000 Attachments: 2021.08.12_MDC_-_Maxwell_MAIN.pdf; 2021.08.12_MDC_-_Maxwell_PASSWORD.pdf The drive is ready to be sent to MDC. The cover letters are attached; if they look good to go, we can leave the drive for FedEx pickup. Thanks so much! From: Sent: Thursday, August 12, 2021 2:26 PM To: (USANYS) [Contractor] < Cc: C ; (USANYS) < 1< Subject: RE: US v. Maxwell - discovery production Great, thank you so much! (USANYS) [Contractor] From: (USANYS) [Contractor] Sent: Thursday, August 12, 2021 2:19 PM To: (USANYS) [Contractor] Cc: < )'; (USANYS) S Subject: RE: US v. Maxwell - discovery production We'll work on loading the files to their drive this afternoon; it shouldn't take long. If helpful, below are our explanations for how to open certain file types or explanations for why certain file types will not open or play audio: • 3501.007 o 3501.007-007: This file is I.txt file. It can be opened with any text editor application. o 3501.007-008: This file is an .mp4 file that ploys audio. It opens and is audible. o 3501.007-009: This file is 1./son file. It can be read likeI.txt file and opened with any text editor application. • 3501.075 -- o 3501.075-013: This file is Side B from an original tope recording of It opens but does not contain content. • 3501.091 o 3501.091-007: This file is Side B from an original tope recording of It opens but does not contain content. • 3501.149 o 3501.149-043: This folder contains two .BUP files, two .IFO files, and 4 .VOB files. It contains video files and related files. Regarding 3501.149-043, and I are not sure of the source (i.e. what Florida entity produced it and when) of the video files. Given that, we were also not sure if deleting the accessory files that don't contain any viewable/listenable info would affect the rest of the video, so we produced the entire thing under one 3500 number. EFTA00098331 We'll let you know when the drive is loaded and ready to be sent to MDC via FedEx. Thanks! From: Sent: Thursday, August 12, 2021 1:24 PM To: (USANYS) [Contractor] Cc: Subject: FW: US v. Maxwell - discovery production you mind handling this, please? From: Christian Everdell < Sent: Thursday, August 12, 2021 1:23 PM To: Menninger' Cc: (USANYS) ; Mark S. Cohen (USANYS) (Contractor] >; 'Jeff Pagliuca' < >; 'Bobbi Sternheim' )< >; Subject: RE: US v. Maxwell - discovery production Hi (USANYS) < (USANYS) [Contractor] (USANYS) [Contractor] <I Below are the files that our client is having trouble opening or are inaudible. They are all part of the non-testifying 3500 materials. Please load replacement copies of these onto the drive. 1. 3501.007-007 to 009 2. 3501.075-013 3. 3501.091-007 4. 3501.149-043 Thanks, Chris From: Sent: Monday, August 9, 2021 8:02 PM To: Christian Everdell < >; Mark S. Cohen < Menninger' 'Jeff Pagliuca' < >; 'Bobbi Sternheim' Cc: (USANYS) Subject: RE: US v. Maxwell - discovery production (USANYS) [Contractor] (USANYS) [Contractor] Got it, thanks very much. Once we hear from you what materials Ms. Maxwell needs on this drive, we will get it loaded. From: Christian Everdell Sent: Monday, August 9, 2021 4:39 PM To: >; Mark S. Cohen Menninger' 'Jeff Pagliuca' 'Bobbi Sternheim' EFTA00098332 Cc: >; (USANYS) < >; I< >; (USANYS) [Contractor] < (USANYS) [Contractor] Subject: RE: US v. Maxwell - discovery production The drive is ID CG0001 and the PIN is Thanks. From: [marlto Sent: Monday, August 09, 2021 1:32 PM To: Christian Everdell• Mark S. Cohen• ' Menninger'; 'Jeff Pagliuca'; 'Bobbi Sternheim' Cc: (USANYS); I ) (USANYS) [Contractor] Subject: RE: US v. Maxwell - discovery production Hi Chris, The drive has arrived at our office. Is there I particular password we should use for this drive? Thanks, (USANYS) [Contractor]; From: Sent: Monday, August 9, 2021 12:52 PM To: Christian Everdell < >; Mark S. Cohen < Menninger' Cc: < 'Jeff Pagliuca' < >; 'Bobbi Sternheim' >; (USANYS) < >; >; (USANYS) [Contractor] (USANYS) [Contractor] < Subject: RE: US v. Maxwell - discovery production Got it, thanks very much. From: Christian Everdell Sent: Monday, August 9, 2021 12:49 PM To: < Menninger' < Cc: >; Mark S. Cohen >; 'Jeff Pagliuca' < >; 'Bobbi Sternheim' >; (USANYS) < I< (USANYS) [Contractor] (USANYS) [Contractor] < Subject: RE: US v. Maxwell - discovery production It was addressed to From: [na Sent: Monday, August 09, 2021 12:47 PM To: Christian Everdell• Mark S. Cohen• Menninger'; 'Jeff Pagliuca'; 'Bobbi Sternheim' Cc: (USANYS); I >; (USANYS) [Contractor]; EFTA00098333 (USANYS) [Contractor] Subject: RE: US v. Maxwell - discovery production Thanks very much. Was the drive addressed to me or someone else in the office? Once we track it down, we'll be happy to load it with whatever materials you request from the prior productions. Best, From: Christian Everdell < Sent: Monday, August 9, 2021 12:43 PM To: ) < >; Mark S. Cohen Menninger' < >; 'Jeff Pagliuca' 'Bobbi Sternheim' Cc: I< >; Subject: RE: US v. Maxwell - discovery production (USANYS) < > (USANYS) [Contractor] (USANYS) [Contractor] <I Thanks, We have also just shipped another padlock drive to you, which may have already arrived. Ms. Maxwell has told us she is having some trouble opening some of the discovery she recently received. I am trying to get s sense of which files she is having trouble with. Once I do, I will likely ask you to load the new padlock drive with some previously produced files. Thanks. From: [mailto: Sent: Monday, August 09, 2021 8:42 AM To: Christian Everdell• Mark S. Cohen• ' Menninger'• 'Jeff Pagliuca'; 'Bobbi Stemheim' Cc: (USANYS); I ) (USANYS) [Contractor] Subject: RE: US v. Maxwell - discovery production Chris, (USANYS) [Contractor]; We received the drives and have finished loading them. As you requested, the padlock drive does not have McAfee encryption software and instead uses the encryption on the drive. That drive for counsel is available to be picked up at 1 St. Andrews now. The drive for Ms. Maxwell is being shipped out to the MDC via FedEx today as well. Best, Assistant United States Attorney Southern District of New York From: Christian Everdell < Sent: Friday, August 6, 2021 12:18 PM EFTA00098334 To: >; Mark S. Cohen Menninger' >; 'Jeff Pagliuca' < >; 'Bobbi Sternheim' Cc: >; (USANYS) < < (USANYS) [Contractor) Subject: RE: US v. Maxwell - discovery production I should have mentioned this. To open the padlock drive, please use the info below: ID: PIN: Thanks, Chris From: Christian Everdell Sent: Frida Au ust 06 2021 11:15 AM To: t• Mark S. Cohen; Menninger; Jeff Pagliuca; Bobbi Sternheim Cc: (USANYS); I Subject: RE: US v. Maxwell - discovery production (USANYS) [Contractor]; We are sending. messenger to you shortly with one 1 TB USB drive and one 1 TB padlock drive. The USB drive is for Ms. Maxwell and the padlock drive is for counsel. We will mark them accordingly. We have had some issues in the past with extracting information from the McAfee encryption program that you use to encrypt the data on the drives. Because the padlock drive already has onboard encryption, can you not use the McAfee encryption software on that drive? Please advise. Thanks, Chris From: [mailto Sent: Thursday, August 05, 2021 8:53 PM To: Christian Everdell; Mark S. Cohen. Menninger; Jeff Pagliuca; Bobbi Sternheim Cc: (USANYS); I ) Subject: US v. Maxwell - discovery production Counsel, (USANYS) [Contractor] As I previewed in my email to yesterday, we now have I set of discovery materials ready to produce to you. Attached please find the cover letter accompanying this production. For this production, we will need two 500GB hard drives (one for counsel's copy and one for Ms. Maxwell's co y) on which to load the materials. If you would please address those drives to Paralegal Specialist at that will enable us to get the drives loaded more quickly. Best, EFTA00098335 Assistant United States Attorney Southern District of New York EFTA00098336

Related Documents (6)

DOJ Data Set 9OtherUnknown

UNITED STATES DISTRICT COURT

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. x 20 Cr. 330 (AJN) MEMORANDUM IN SUPPORT OF GHISLAINE MAXWELL'S THIRD MOTION FOR RELEASE ON BAIL Bobbi C. Sternheim Law Offices of Bobbi C. Sternheim Christian R. Everdell COHEN & GRESSER LLP Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Attorneys for Ghislaine Maxwell EFTA00090990 INTRODUCTION Ghislaine Maxwell respectfully submits this Memorandum in Support of her Third Motion for Release on Bail. As Ms. Maxwell has stated on numerous occasions and reaffirms here: she has no intention or desire to leave this country. She is an American citizen, has lived in United States for 30 years, has strong family ties and the support of friends and family residing in this country. She wants nothing more than to remain in the United States under whatever conditions the Court deems necessary so that she can effectively prepare fo

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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

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DOJ Data Set 9OtherUnknown

LBUCmaxl

120 LBUCmaxl UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. Before: 20 CR 330 (AJN) Jury Trial New York, N.Y. November 30, 2021 8:50 a.m. HON. ALISON J. NATHAN, APPEARANCES DAMIAN United States Attorney for the Southern District of New York BY: Assistant United States Attorneys HADDON MORGAN AND FOREMAN Attorneys for Defendant BY: JEFFREY S. PAGLIUCA CHRISTIAN R. EVERDELL LAURA A. MENNINGER -and- BOBBI C. STERNHEIM -and- RENATO STABILE Also Present: District Judge , FBI NYPD Sunny Drescher, Paralegal, U.S. Attorney's Office Ann Lundberg, Paralegal, Haddon Morgan and Foreman SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068582 121 LBUCmaxl 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 (Jury not present) THE COURT: Looks like we have everybody. Matt

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DOJ Data Set 9OtherUnknown

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

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DOJ Data Set 9OtherUnknown

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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DOJ Data Set 9OtherUnknown

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

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