EFTA00020426.pdf

248 KB
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Extraction Summary

8
People
7
Organizations
7
Locations
4
Events
3
Relationships
5
Quotes

Document Information

Type: Email chain / legal correspondence
File Size: 248 KB
Summary

This document is an email chain from March 2021 between Ghislaine Maxwell's defense counsel (Christian Everdell) and the U.S. Attorney's Office (SDNY) regarding discovery disputes. The defense raises seven specific issues, including the inability of Maxwell to view files on prison computers, missing email attachments (over 109,000), metadata discrepancies suggesting files were created/modified after seizure, and gaps in Bates numbering. The prosecution responds by explaining technical limitations with the MDC (prison), asserting that metadata reflects the state of files upon FBI seizure or carving, and clarifying that certain images came from physical CDs seized from Epstein's residences in 2019 rather than electronic extractions.

People (8)

Name Role Context
Christian Everdell Defense Attorney
Partner at Cohen & Gresser LLP, representing Ghislaine Maxwell, author of the detailed discovery request.
Jeff Pagliuca Defense Attorney
CC'd on the email chain.
Laura Menninger Defense Attorney
CC'd on the email chain.
Bobbi Sternheim Defense Attorney
CC'd on the email chain.
Thomas J. Powers Legal Team
CC'd on the email chain.
Ghislaine Maxwell Defendant
Referred to as 'client' and 'Ms. Maxwell'; currently held at MDC.
Jeffrey Epstein Deceased Subject
Mentioned in context of 'Epstein's devices', 'Epstein residences', and seized files.
Judge Nathan Judge
Mentioned as the authority to whom an application could be made regarding the MDC drive issue.

Organizations (7)

Name Type Context
USANYS
U.S. Attorney's Office for the Southern District of New York (Prosecution).
Cohen & Gresser LLP
Law firm representing Ghislaine Maxwell.
MDC
Metropolitan Detention Center (where Maxwell is incarcerated).
FBI
Federal Bureau of Investigation (seized devices).
SDFL
Southern District of Florida (mentioned regarding old investigation videos).
PBPD
Palm Beach Police Department (mentioned regarding old investigation videos).
CART
Computer Analysis and Response Team (forensics).

Timeline (4 events)

2019
Searches of Epstein residences where CDs and images were seized.
Epstein residences
2020-11-09
Discovery letter referencing seized images.
N/A
2020-11-18
Discovery production date mentioned in context of missing files.
N/A
USANYS Defense Team
2021-03-16
Email sent regarding highly confidential images.
N/A

Locations (7)

Location Context
Jurisdiction of the case.
MDC
Detention center where Maxwell is held.
Locations searched in 2019.
Cohen & Gresser office location.
Cohen & Gresser office location.
Cohen & Gresser office location.
Cohen & Gresser office location.

Relationships (3)

Christian Everdell Attorney/Client Ghislaine Maxwell
Everdell refers to Maxwell as 'our client' and 'Ms. Maxwell'.
Ghislaine Maxwell Incarceration MDC
Discusses Maxwell's inability to read disks on the 'prison computer' at MDC.
Jeffrey Epstein Investigation Target FBI
References FBI seizing files from Epstein's devices and residences.

Key Quotes (5)

"Our supervisors have indicated that we are not permitted to send a drive that our IT department did not load to the MDC."
Source
EFTA00020426.pdf
Quote #1
"the electronic files recovered from Epstein’s devices have the same metadata on the hard drive that was available when the FBI seized each file."
Source
EFTA00020426.pdf
Quote #2
"A number of the emails in the discovery — over 109,000 — were produced without their attachments"
Source
EFTA00020426.pdf
Quote #3
"A number of electronic documents — over 110,000 — that were extracted from one of Epstein’s devices ... have metadata that indicates a 'date created' ... in July 2020 or afterwards"
Source
EFTA00020426.pdf
Quote #4
"all images within Bates range SDNY_GM_00467566 though SDNY_GM_00514100 were seized during the 2019 searches of Epstein residences."
Source
EFTA00020426.pdf
Quote #5

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