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efta-efta00101935DOJ Data Set 9Other

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DOJ Data Set 9
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EFTA 00101935
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From: " To: ' " < > ,' (USANYS)" Subject: FW: US v. Maxwell - 20 Cr. 330 (MN) - Request to view evidence, highly confidential materials, scenes Date: Tue, 09 Mar 2021 20:56:56 +0000 Inline-Images: image00 1 jpg Proposed response below. Good with you? To my knowledge, that is the only excel spreadsheet in our possession that indexes physical evidence related to this case. The discovery productions also included search warrant returns listing the physical items seized by the FBI's New York Office during the 2019 searches of Jeffrey Epstein's residences in New York and the U.S Virgin Islands, but they are not contained in a spreadsheet. As a courtesy, I have asked the FBI whether it would be possible to provide us with a similar excel index reflecting the physical evidence seized by the FBI's New York Office, though it may take some time to complete such an index. Best, From: Laura Menninger <Imenninger@hmflaw.com> Sent: Tuesday, March 9, 2021 3:44 PM To: ) )< ›; (

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From: " To: ' " < > ,' (USANYS)" Subject: FW: US v. Maxwell - 20 Cr. 330 (MN) - Request to view evidence, highly confidential materials, scenes Date: Tue, 09 Mar 2021 20:56:56 +0000 Inline-Images: image00 1 jpg Proposed response below. Good with you? To my knowledge, that is the only excel spreadsheet in our possession that indexes physical evidence related to this case. The discovery productions also included search warrant returns listing the physical items seized by the FBI's New York Office during the 2019 searches of Jeffrey Epstein's residences in New York and the U.S Virgin Islands, but they are not contained in a spreadsheet. As a courtesy, I have asked the FBI whether it would be possible to provide us with a similar excel index reflecting the physical evidence seized by the FBI's New York Office, though it may take some time to complete such an index. Best, From: Laura Menninger <Imenninger@hmflaw.com> Sent: Tuesday, March 9, 2021 3:44 PM To: ) )< ›; (USANYS) Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com) <ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com> Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes Thank you. Is that the only index of physical evidence available? Laura A. Menninger I Partner Haddon, Morgan & Foreman, P.C. 150 E. 10th Avenue I Denver, CO 80203 +1 303 831 7364 (Office) Imenninger@hmflaw.com From: Sent: Tuesday, March 9, 2021 1:38 PM To: Laura Menninger <ImenningeSimflaw.com>; II (USANYS) Cc: Jeff Pagliuca <jpagliucaPhmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdellPcohengresser.com) <ceverdell@cohengresser.com>• 'BOBBI C STERNHEIM' <bcsternheim@mac.com> Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes Counsel, EFTA00101935 In advance of our call tomorrow, I wanted to send a copy of the attached index of physical items in FBI custody from the FBI-Miami office, which we previously produced to you as part of our August 21, 2020 discovery production. Also included in that August 21, 2020 production were scans of numerous items listed on the index. Those scans can be found within Bates range SDNY_GM_00172218-SDNY_GM_00173007. It may be useful to reference some of those items during our conversation tomorrow, so I wanted to make sure you were aware of them. Best, Assistant United States Attorney Southern District of New York 1 St. Andrew's Plaza New York, NY 10007 From: Sent: Tuesday, March 9, 2021 2:03 PM To: 'Laura Menninger' <Imenninge hmflaw.com>• (USANYS) Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>• Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com) <ceverdeIl@cohengresser.com>. 'BOBBI C STERNHEIM' <bcsternheim@mac.com> Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes Yes, that works for us, thank you very much. We can use the below dial-in: Dial-in: Code: Best, From: Laura Menninger <Imenning @hmflaw.com> Sent: Tuesday, March 9, 2021 11:19 AM To: ) <->; (USANYS) .tz > Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>• Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com) <ceverdeIl@cohengresseccom>. 'BOBBI C STERNHEIM' <bcsternheim@mac.com> Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes Good morning, We are free at 1:30 p.m. ET / 11:30 a.m. MST tomorrow. Would that work? We are generally free thereafter, so please suggest another later time if not. Thank you, Laura Laura A. Henninger I Partner Haddon, Morgan & Foreman, P.C. EFTA00101936 150 E. 10th Avenue I Denver, CO 80203 +I 303 831 7364 (Office) Imenninger(iihnfflaw.com From: Sent: Tuesday, March 9, 2021 8:36 AM To: Laura Menninger <ImenningeSimflaw.com>. (USANYS) Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>• Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com) <ceverdell@cohengresser.com>• 'BOBBI C STERNHEIM' <bcsternheim@mac.com> Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes Good morning, It would be helpful to have a call to discuss the requests contained in this letter. Are there times tomorrow when you would be available to speak, please? Thank you, Assistant United States Attorney Southern District of New York I St. Andrew's Plaza New York, NY 10007 From: Laura Menninger <Imenningejhmflaw.com> Sent: Monday, March 8, 20212:03 PM To: >; <->• (USANYS) Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>• Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com) <ceverdell@cohengresser.com>• 'BOBBI C STERNHEIM' <bcsternheim@mac.com> Subject: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes Counsel — Please see attached correspondence. -Laura Laura A. Menninger Haddon, Morgan and Foreman, P.C. 150 East 10th Avenue Denver, Colorado 80203 Main 303.831.7364 FX 303.832.2628 EFTA00101937 ImenningerPhmflaw.com www.hmflaw.com CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages attached to it may contain information that is confidential or legally privileged. If you are not the intended recipient, or a person responsible for delivering it to the intended recipient, you are hereby notified that you must not read this transmission and that any disclosure, copying, printing, distribution or use of any of the information contained in or attached to this transmission is STRICTLY PROHIBITED. If you have received this transmission in error, please notify the sender by telephone or return e-mail and delete the original transmission and its attachments without reading or saving it in any manner. Thank you. EFTA00101938

Related Documents (6)

DOJ Data Set 9OtherUnknown

To: Laura Mennin er <Imennin e

From: To: Laura Mennin er <Imennin e mflaw.com>, " " (USANYS)" Cc: Jeff Pagliuca ipagliuca@hmflaw.com>, "Christian R Everdell - Cohen & Gresser LLP (Ceverdell@cohengressercom)" <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: Tue, 06 Apr 2021 02:48:27 +0000 Inline-Images: image001.jpg Laura, Thank you for your email and for your understanding as we work through the logistics of arranging this review. Your modifications and clarifications are acceptable to us. Below I address each specifically: • The FBI can arrange for a lawyer, investigator, and paralegal to inspect and photograph the precluded items at the Bronx warehouse either next week or the week after. Please let us know what day you would like to arrange for that inspection, and I will coordinate with the FBI accordingly. I would suggest trying to schedule this visit early

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DOJ Data Set 9OtherUnknown

From: Laura Menninger <Imenninger®hmflaw con ,

From: Laura Menninger <Imenninger®hmflaw con , To: II III I II (USANYS)" Cc: Jeff Pagliuca ipagliuca®Innflaw.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: Mon, 15 Mar 2021 19:00:36 +0000 Inline-Images: image00 1 jpg Now that the FBI team is back, when do you expect to have answers to all of the questions posed? If I had an idea of when you would have answers, it could help me answer your question. At a minimum, it would not seem to take too much time to know when someone can open the FBI vault and allow the attorneys to make an initial view of the evidence. Also, I understand the FBI did not prepare an inventory of their evidence when they seized it from NY and LSJ, so I don't think we need to wait for them to now prepare an inventory before we start

5p
DOJ Data Set 9OtherUnknown

To: Laura Mennin er

From: To: Laura Mennin er , " " (USANYS)" Cc: Jeff Pagliuca "Christian R Everdell - Cohen & Gresser LLP (ceverdell a cohen sser.com)" 'BOBBI C STERNHEIM' Subject: RE: US v. Maxwell - 20 Cr. 330 (MN) - Request to view evidence, highly confidential materials, scenes Date: Wed, 07 Apr 2021 04:09:12 +0000 Attachments: New_York Evidence List_- Annotated by_AUSA.xlsx; Florida Evidence List_- Annotatect by_AUS—A.xlsx;—Florida_Evidence_Sub-Item_List_- _—AnnotatecT by_AUSA.xlsx Inline-Images: image00 1 jpg Good evening, Today, the Marshals confirmed that they will produce Ms. Maxwell to 500 Pearl Street on April 13, 2021 and every day thereafter until the evidence review is complete. My understanding is that Ms. Maxwell should arrive to 500 Pearl Street at approximately 9:30am each morning. So we are confirmed for evidence review in the proffer rooms on the 5th floor of the 500 Pearl Street courthouse beginning at 9:30am on April 13th. I will plan to be present and to contin

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DOJ Data Set 9OtherUnknown

To: Laura Mennin er <Imennin e

From: " <as To: Laura Mennin er <Imennin e mflaw.com>, " " (USANYS)" Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>, "Christian R Everdell - Cohen & Gresser LLP (ceverdellgcohengresser.com)" <ceverdellgcohengresser.com>, 'BOBBI C STERNHEIM' <bcstemheimgmac.com> Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes Date: Wed, 07 Apr 2021 19:44:26 +0000 Inline-Images: image001.jpg Hi Laura, The Bronx warehouse is located at 2350 Lafayette Ave, Bronx, NY. There is plenty of street parking outside of the building. Whatever day you wish to have the review conducted at the warehouse, an AUSA and an agent will meet the attorney, investigator, and paralegal at the warehouse to escort them into the building to the evidence review room. The AUSA will remain present at the warehouse to answer any questions that may arise. The FBI has informed me that they can make the evidence available for review at the warehouse any day next

15p
DOJ Data Set 9OtherUnknown

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

10p
DOJ Data Set 9OtherUnknown

From: '

From: ' (NY) (FBI)" To:' Cc: ' Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes Date: Wed, 07 Apr 2021 21:35:17 +0000 Inline-Images: image001.jpg I'm available. Feel free to call anytime. I'll coordinate with evidence and let you know. From: Sent: Wednesday, April 7, 2021 4:29 PM To: (NY) (FBI) < > Cc: (USANYS) < INYPD)< > Subject: (EXTERNAL EMAIL] - FW: US v. Maxwell 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes Hi As you can see below, the defense wants to the do the Bronx warehouse review on April 12th. Would you please coordinate with the warehouse and let me know how to arrange the logistics for this? Also, let me know when you're available for a call to discuss several of the other issues raised in this most recent email. Thanks, From: Laura Menninger Sent: Wednesday, April 7, 2021 4:23 PM To: ) ; 1 <->; (USANYS) Cc: Jeff Pa liuca ; Christian R Eve

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