| Connected Entity | Relationship Type |
Strength
(mentions)
|
Documents | Actions |
|---|---|---|---|---|
|
person
Laura Menninger
|
Opposing counsel |
2
|
2 | |
|
person
CHRISTIAN EVERDELL
|
Opposing counsel |
2
|
2 | |
|
person
Redacted Recipient
|
Business associate |
2
|
2 | |
|
person
Recipient
|
Professional investigative |
1
|
1 | |
|
person
Clara Moran
|
Professional collaborative |
1
|
1 | |
|
person
USANYS Staff (Redacted)
|
Business associate |
1
|
1 | |
|
person
FBI Analyst (Redacted)
|
Professional collaboration |
1
|
1 | |
|
person
Jeff Pagliuca
|
Opposing counsel |
1
|
1 | |
|
person
Martin G. Weinberg
|
Opposing counsel |
1
|
1 | |
|
person
FBI
|
Legal representative |
1
|
1 | |
|
person
Redacted Recipient (USANYS)
|
Legal representative |
1
|
1 | |
|
person
CHRISTIAN EVERDELL
|
Legal representative |
1
|
1 | |
|
person
Laura Menninger
|
Legal representative |
1
|
1 |
This document contains a chain of emails between Ghislaine Maxwell's defense team (Haddon, Morgan & Foreman; Cohen & Gresser) and the US Attorney's Office regarding the logistics of reviewing evidence for the case US v. Maxwell. The correspondence details disputes and arrangements for reviewing 'highly confidential' materials, including over 2,100 nude/partially nude images seized from Jeffrey Epstein's devices, as well as physical evidence stored at an FBI warehouse in the Bronx. Specific items discussed include massage tables, plaster busts of female torsos, a stuffed dog, cash held at Federal Plaza, and various electronic recording media.
This document is a chain of emails between the U.S. Attorney's Office (SDNY) and defense counsel for Ghislaine Maxwell (Laura Menninger) from March 2021. The correspondence concerns the scheduling of a review of 'highly confidential images' and physical evidence at 500 Pearl Street, as well as the production of indices listing items seized by the FBI from Jeffrey Epstein's residences in New York and the Virgin Islands in 2019. The prosecutor clarifies which items are indexed in spreadsheets versus search warrant returns and coordinates a phone call to discuss these matters.
This document is an email chain between attorney Jack Scarola and an Assistant United States Attorney (SDNY) regarding the prosecution of Jeffrey Epstein. Scarola identifies a victim who was molested in Florida beginning at age 14 and received lingerie gifts from Epstein. The correspondence coordinates a potential meeting between federal investigators and the victim in Florida.
This document contains a series of email exchanges between Ghislaine Maxwell's defense team (led by Laura Menninger) and the US Attorney's Office regarding the logistics of reviewing discovery evidence in March and April 2021. The correspondence details disputes over the location of the review (FBI Bronx Warehouse vs. 500 Pearl Street courthouse), specifically concerning 'bulky' items such as massage tables, plaster busts, and framed art which the government refused to transport. Significant discussion focuses on the protocols for reviewing 'Highly Confidential' materials, including approximately 2,100 nude or obscene electronic images seized from Jeffrey Epstein's devices, which required specific viewing conditions on non-networked laptops due to their nature.
This document is an email chain from October 2019 between Sigrid McCawley (Boies Schiller Flexner) and an Assistant US Attorney (SDNY) coordinating interviews for several Epstein victims. The correspondence discusses scheduling around a 'victims' meeting' on October 23, 2019, and visa/passport issues for a specific victim who was 'brought to the US by Epstein a number of times.' The emails also mention a set of sisters, one of whom had already been interviewed by the SDNY.
This document is an email chain from June 2021 between an Assistant US Attorney (SDNY) and a likely bank representative regarding JPMC account documents for Jeffery Epstein and Ghislaine Maxwell. The correspondence provides a summary table listing Maxwell's roles (President, Treasurer, Authorized Signer) for various entities including Hyperion Air, Freedom Air, and JEGE Inc. It also details a specific transaction from October 1999 where $18.3 million was transferred to Maxwell from the Financial Trust Company account, sourced from the sale of a JP Morgan money market fund.
This document is an email chain from August 2, 2019, between the US Attorney's Office (SDNY) and Defense Counsel regarding the Jeffrey Epstein case. The correspondence details a dispute over whether specific discovery materials, including statements to law enforcement and cell site data, should be filed under seal or publicly with redactions. The prosecution accuses the defense of violating a protective order by publicly filing sensitive exhibits, while the defense discusses logistical issues regarding getting the defendant's affidavit signed at the MCC without the legal team acting as witnesses.
This document is a series of emails from July 2019 between defense attorney Michael Bachner and the SDNY/FBI regarding the Epstein investigation. The correspondence coordinates a 'reverse proffer' meeting where the government intends to persuade Bachner's female client to cooperate to avoid potential arrest. Bachner explicitly notifies the government that his client intends to invoke her Fifth Amendment privilege if called to testify before a Grand Jury.
This document is a chain of emails between Ghislaine Maxwell's defense counsel (Christian Everdell) and the US Attorney's Office regarding various discovery disputes in early 2021. Key issues include technical difficulties with Maxwell accessing discovery on prison computers, requests for unredacted FBI reports from 2006 found on Epstein's devices, and clarification regarding 'missing' pages from flight logs produced by pilot David Rodgers (which the prosecution explains were re-numbered/included in a different file). The defense also raises concerns about a Daily Beast article referencing a search warrant affidavit, which the prosecution confirms was unsealed by the court in New Hampshire, not leaked by their office.
Requesting a citation check on a portion of a brief; instructing to highlight cites where documents are unavailable.
Returning partial work (up to page 5) via attachment 'Govt_Reply_v2_MH.docx'; explaining they have class until 9:10 PM and cannot finish until the next morning.
Submission of Government's opposition to defense motions in limine, with attachments including exhibits and omnibus opposition.
Request to schedule an evidence inspection with the defendant present at a proffer room, coordinating with Marshals and defense counsel flying in from out of state.
Notification of additional discovery production and supplemental production of testifying and non-testifying witness material via USAfx. Discussion of logistics for sending materials (CD or Drive) to Ms. Maxwell at the MDC.
Sender attaches the last set of Motions in Limine (MILs) for review, mentioning four documents related to suppression of ID, exhibits, forbidden words, and irrelevant words. Mentions waiting for an expert's input by noon the next day.
Discussing attached responses to motions (MILs), specifically regarding exhibits, suppressing MV-4's ID, and upcoming motions precluding reference to 'victims' and 'rape'.
Follow up regarding a telephone conference held by Judge Nathan, providing details about dial-in information for the defendant.
Requesting comments on the draft joint proposed request to charge by Sunday, October 24, ahead of the court deadline on October 27.
Submission of Government motions in limine and cover letters, requesting filing under seal.
Request to discuss defense MIL 4 and how to respond, referencing an attachment '4._Motion_to_Exclude_Accuser-3_Evidence.pdf'. Sender notes the recipient briefed a similar issue previously.
Request to add citations to respective dockets for a document. Mentions 3500 folders and clarifies that one victim brought suit under her real name while Victim-1's case is Doe v. Indyke.
Discussing a letter filed by Maxwell's counsel regarding legal mail and a court order to respond by 5 pm that day. Asking for a call.
Here is the current final version. Let me know if you have any edits, thanks!
Counsel, Please see the attached letter.
Discussing a draft cover letter for spreadsheets to be produced that night, asking for input on language like 'as a courtesy'.
Coordination of legal discovery production including witness lists, 3500 material, and government exhibits.
Submitting joint proposed juror questionnaire and voir dire; requesting they be accepted under seal; notifying Court that Jencks Act material was produced to defense.
Submission of joint proposed juror questionnaire and voir dire; request to seal; notification that Jencks Act material was produced to defense.
Here’s a quick draft of the 12.2 letter we discussed.
Discussing an interview conducted that day with a female subject, attaching notes, a tipline call report, and PBPD report pages.
Prosecution sending draft financial exhibits to facilitate conversation about identifying a witness from JP Morgan.
Notification of additional discovery production via USAfx and arrangements for delivering data (CD vs Drive) to Ms. Maxwell at the MDC.
Attached for your review is the draft of our Rule 404(b) letter. It's due on Monday.
Follow up regarding missing handwritten notes for interviews from 2006 needed for 3500 materials (Jencks Act disclosures) preparation for an upcoming deadline.
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