| 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.
Notification of additional discovery production via FTP site for counsel and via CD for Ms. Maxwell at MDC. Mentions conversion of Excel files to PDFs for proper review.
Sender informs recipient about a document (USGME01220266.doc) found in Relativity that was missing from a specific witness folder.
Informing counsel of two upcoming court appearances: an arraignment on April 23 and a bail appeal argument on April 26.
Request to create a potential testifying witness folder for [Redacted] and include attached items.
Requesting Maxwell be produced at 500 Pearl Street from April 13-16 to review physical evidence in FBI custody.
Attached, thanks.
Informs that a lawsuit was resolved and dismissed by Judge Koeltl. Sender plans to ask for materials disclosed to Maxwell's team during a meeting the following day.
Email transmitting an attachment titled '2021-03-29_Letter_Re_Discovery_Requests_Re_FOIA.pdf'
Submission of revised memorandum on Tova Noel's deferred prosecution application.
Sender found an email and attachment during review and is circulating it for further review.
Email transmitting two PDF attachments titled '[Redacted]_Deposition_Vol._1.pdf' and '[Redacted]_Deposition_Vol._II.pdf' dated 2009-12-04.
Submission of Government's letter relating to redactions filed on ECF, proposed redactions to omnibus memorandum of law, and Exhibit 11.
Notification of discovery production regarding victims not referenced in Indictment S1 20 Cr. 330 (AJN), request for FTP link, and notification of CD delivery to MDC.
Informing counsel that FBI team is out of office; discussing scheduling a visit to 500 Pearl Street to review highly confidential images on a laptop around Thursday 5/18.
Discussion regarding document tagging in e-discovery software. Sender notes an attached document (2007 subpoena) was marked 'potential Brady' but believes it is 'work product' and asks for verification before changing the tag.
Clarifying that the provided Excel spreadsheet is not the only index of physical items; mentioning search warrant returns from 2019 searches of Epstein's NY and USVI residences; offering to ask FBI for a similar index for NY office items.
Asking if the provided index is the only one available.
Sending copy of index of physical items from FBI-Miami office produced Aug 21, 2020, and referencing scans within Bates range SDNY_GM_00172218-SDNY_GM_00173007.
Sending a draft of the government's opposition to Maxwell's third bail motion for review.
Initial request with attached correspondence.
Thank you.
Notification that Ghislaine Maxwell has submitted a third motion for bail and that it is anticipated to be resolved 'on the papers'.
Transmission of discovery production files and password for the US v. Maxwell case.
Attached, thanks!
Circulates the most recent draft of the NPA brief. Expresses difficulty with the second half of the arguments and requests review.
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