EFTA00025206.pdf

163 KB

Extraction Summary

5
People
5
Organizations
3
Locations
2
Events
2
Relationships
2
Quotes

Document Information

Type: Email chain / legal correspondence
File Size: 163 KB
Summary

This document is an email chain from March 2021 between defense attorneys for Ghislaine Maxwell (Laura Menninger, et al.) and Assistant United States Attorneys for the Southern District of New York. The correspondence concerns scheduling a call to discuss evidence requests and includes the transmission of an index of physical items held in FBI custody by the Miami office. The prosecutor references a previous discovery production from August 2020 and specific Bates ranges for scanned items.

People (5)

Name Role Context
Laura Menninger Partner, Haddon, Morgan & Foreman, P.C.
Defense counsel for Ghislaine Maxwell; coordinating call with prosecution.
Jeff Pagliuca Attorney, Haddon, Morgan & Foreman, P.C.
CC'd on legal correspondence.
Christian R. Everdell Attorney, Cohen & Gresser LLP
CC'd on legal correspondence.
Bobbi C. Sternheim Attorney
CC'd on legal correspondence.
[Redacted] Assistant United States Attorney
Prosecutor (Southern District of New York); arranging call and providing evidence index.

Timeline (2 events)

2020-08-21
Previous discovery production mentioned by AUSA, including scans of items in FBI custody.
N/A
2021-03-10
Scheduled conference call between Defense Counsel (Menninger) and SDNY Prosecutors.
Teleconference
Laura Menninger [Redacted AUSA]

Relationships (2)

Laura Menninger Colleagues Jeff Pagliuca
Both work at Haddon, Morgan & Foreman, P.C. and are on the same email chain as defense counsel.
Laura Menninger Co-Counsel Christian R Everdell
Both representing the defense in US v. Maxwell.

Key Quotes (2)

"I wanted to send a copy of the attached index of physical items in FBI custody from the FBI-Miami office"
Source
EFTA00025206.pdf
Quote #1
"Those scans can be found within Bates range SDNY_GM_00172218-SDNY_GM_00173007."
Source
EFTA00025206.pdf
Quote #2

Full Extracted Text

Complete text extracted from the document (4,828 characters)

From: [REDACTED] <[REDACTED]>
To: Laura Menninger , "[REDACTED]" <[REDACTED]>, "[REDACTED] (USANYS)" <[REDACTED]>
Cc: Jeff Pagliuca , "Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)" , 'BOBBI C STERNHEIM'
Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Date: Tue, 09 Mar 2021 20:38:29 +0000
Attachments: SDNY_GM_00173008_[CONFIDENTIAL].xlsx
Inline-Images: image001.jpg
Counsel,
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,
[REDACTED]
[REDACTED]
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
[REDACTED]
From: [REDACTED]
Sent: Tuesday, March 9, 2021 2:03 PM
To: 'Laura Menninger' ; [REDACTED] (USANYS) <[REDACTED]>
Cc: Jeff Pagliuca ; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com) ; 'BOBBI C STERNHEIM'
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: [REDACTED]
Code: [REDACTED]
Best,
[REDACTED]
EFTA00025206
From: Laura Menninger
Sent: Tuesday, March 9, 2021 11:19 AM
To: [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] (USANYS) <[REDACTED]>
Cc: Jeff Pagliuca ; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com) ; 'BOBBI C STERNHEIM'
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. Menninger | Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue | Denver, CO 80203
+1 303 831 7364 (Office)
lmenninger@hmflaw.com
From: [REDACTED]
Sent: Tuesday, March 9, 2021 8:36 AM
To: Laura Menninger ; [REDACTED] (USANYS) <[REDACTED]>
Cc: Jeff Pagliuca ; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com) ; 'BOBBI C STERNHEIM'
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,
[REDACTED]
[REDACTED]
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
[REDACTED]
From: Laura Menninger
Sent: Monday, March 8, 2021 2:03 PM
To: [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] (USANYS) <[REDACTED]>
Cc: Jeff Pagliuca ; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
EFTA00025207
; 'BOBBI C STERNHEIM'
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
lmenninger@hmflaw.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.
EFTA00025208

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