EFTA00028585.pdf

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Extraction Summary

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

Document Information

Type: Legal email correspondence (discovery dispute)
File Size: 389 KB
Summary

This document is an email chain between Ghislaine Maxwell's defense team (Cohen & Gresser; Haddon, Morgan & Foreman) and the US Attorney's Office (SDNY) regarding discovery disputes. The defense raises seven key issues, including over 109,000 emails missing attachments, metadata discrepancies on files extracted from Epstein's devices, and difficulties providing discovery materials to Maxwell at the MDC due to technical and bureaucratic limitations. The prosecution responds with technical explanations regarding FBI CART processes, 'carved' or deleted files lacking metadata, and the conversion of VHS/cassette tapes.

People (8)

Name Role Context
Christian Everdell Defense Attorney
Partner at Cohen & Gresser LLP, representing Ghislaine Maxwell. Initiates the list of 7 discovery issues.
Laura Menninger Defense Attorney
Partner at Haddon, Morgan & Foreman, P.C., representing Ghislaine Maxwell. Follows up on metadata and file conversion...
Jeff Pagliuca Defense Team
CC'd on the correspondence.
Bobbi Sternheim Defense Team
CC'd on the correspondence.
[Redacted] Prosecutor
Assistant United States Attorney(s) (USANYS) handling the case and responding to discovery requests.
Ghislaine Maxwell Defendant
Referred to as 'Ms. Maxwell' or 'client'. Issues involve her ability to view discovery on prison computers.
Jeffrey Epstein Deceased Subject
Referenced regarding devices seized from his residences in 2019.
Judge Nathan Judge
The judge overseeing the case, to whom the parties may apply for orders regarding MDC issues.

Timeline (3 events)

2019
Searches of Epstein residences where CDs and devices were seized.
Epstein Residences
FBI
November 9, 2020
Discovery production date (SDNY011).
N/A
USANYS Defense Team
October 20, 2020
Discovery production date (SDNY005).
N/A
USANYS Defense Team

Relationships (3)

Christian Everdell Attorney-Client Ghislaine Maxwell
Everdell refers to Maxwell as 'our client' and advocates for her access to discovery materials.
Laura Menninger Co-Counsel Christian Everdell
Both are defense attorneys on the email chain representing the same interests.
Jeffrey Epstein Investigation Target FBI
Document discusses devices and CDs seized by FBI from Epstein's residences.

Key Quotes (5)

"A number of the emails in the discovery — over 109,000 — were produced without their attachments"
Source
EFTA00028585.pdf
Quote #1
"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
EFTA00028585.pdf
Quote #2
"For files that were carved or deleted, no metadata was recovered, so none is viewable."
Source
EFTA00028585.pdf
Quote #3
"Our supervisors have indicated that we are not permitted to send a drive that our IT department did not load to the MDC."
Source
EFTA00028585.pdf
Quote #4
"The videos from SDNY005... were converted by a vendor from VHS and cassette tapes, so there is no metadata to provide."
Source
EFTA00028585.pdf
Quote #5

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