Email Chain / Legal Correspondence - EFTA00025037

Processing Document...

0%

Initializing...

Extraction Summary

6

People

2

Organizations

1

Locations

2

Events

2

Relationships

4

Quotes

Document Information

Type: Email chain / legal correspondence

File Size: 140 KB

Summary

This document is an email chain from October 2021 between the defense team for Ghislaine Maxwell (Christian Everdell, Bobbi Sternheim, etc.) and the US Attorney's Office (SDNY). The correspondence concerns the scheduling and procedure for filing a 'request to charge' (jury instructions) with Judge Nathan. The parties discuss extensions, the possibility of filing separate requests rather than a joint one, and agree to a schedule where the Government files first, followed by the Defense's redline or separate filing in early November.

People (6)

Name	Role	Context
Christian Everdell	Defense Attorney	Primary correspondent for the defense team, negotiating deadlines with SDNY.
Bobbi C Sternheim	Defense Attorney	Recipient of emails, part of the defense team.
Jeff Pagliuca	Defense Attorney	Recipient of emails, part of the defense team.
Laura Menninger	Defense Attorney	Recipient of emails, part of the defense team.
Judge Nathan	Judge	The judge presiding over the case to whom the letters and charges are addressed.
[Redacted Name]	Assistant United States Attorney	Primary correspondent for the Government (SDNY), negotiating with Everdell.

Organizations (2)

Name	Type	Context
SDNY		Southern District of New York (US Attorney's Office), representing the Government.
USANYS		United States Attorneys New York South (appearing in email header).

Timeline (2 events)

2021-10-27

Original due date for the joint proposed request to charge (RTC) to the Court.

The Court (Judge Nathan)

Defense Team SDNY

View

2021-11-03

Proposed deadline for the defense redline or separate RTC.

The Court

Defense Team

View

Locations (1)

Location	Context
Southern District of New York	Jurisdiction of the legal proceedings.

Relationships (2)

Christian Everdell → Colleagues/Co-Counsel → Bobbi C Sternheim

Copied on same defense team emails.

Christian Everdell → Opposing Counsel → [Redacted] (SDNY)

Negotiating deadlines and filing procedures via email chain.

Key Quotes (4)

"I don’t think everyone from SDNY needs to be on this call, but I leave that to you."

Source

EFTA00025037.pdf

Quote #1

"Attached is the letter we intend to file with the Court regarding the extension to file the jury charge."

Source

EFTA00025037.pdf

Quote #2

"We know Judge Nathan asked for a joint RTC, but what about asking Judge Nathan to let us file separate ones?"

Source

EFTA00025037.pdf

Quote #3

"Given all of the other things we have going on this week, the defense would like a little more time to submit the joint requests to charge."

Source

EFTA00025037.pdf

Quote #4

Full Extracted Text

Complete text extracted from the document (4,685 characters)

From: Christian Everdell <[REDACTED]>
To: [REDACTED]
Subject: [EXTERNAL] RE: Draft joint proposed request to charge
Date: Mon, 25 Oct 2021 22:58:41 +0000
Attachments: 2021.10.25_Letter_to_Judge_Nathan_re__Extension_of_Time.DOCX

[REDACTED] –

Attached is the letter we intend to file with the Court regarding the extension to file the jury charge. It should reflect everything we discussed on our call earlier today.

Please let me know if you have any issues with it as soon as you can. I’d like to file it in the next hour or so.

Thanks,

Chris

From: [REDACTED]
Sent: Monday, October 25, 2021 2:29 PM
To: Christian Everdell <[REDACTED]>; BOBBI C STERNHEIM <[REDACTED]>; Jeff Pagliuca <[REDACTED]>; Laura Menninger <[REDACTED]>
Cc: [REDACTED]
Subject: RE: Draft joint proposed request to charge

Hi Chris,

That works. I’m around this afternoon – give me a call at [REDACTED] whenever you have a minute.

Thanks,
[REDACTED]

From: Christian Everdell <[REDACTED]>
Sent: Monday, October 25, 2021 1:56 PM
To: [REDACTED]; BOBBI C STERNHEIM <[REDACTED]>; Jeff Pagliuca <[REDACTED]>; Laura Menninger <[REDACTED]>
Cc: [REDACTED]
Subject: [EXTERNAL] RE: Draft joint proposed request to charge

[REDACTED] –

I think I have a way to come to an agreement on this. I know today is extremely busy for all of us, but can you and I have a 5 min. call to discuss? I don’t think everyone from SDNY needs to be on this call, but I leave that to you.

Thanks,

Chris

EFTA00025037

From: [REDACTED]
Sent: Sunday, October 24, 2021 3:10 PM
To: Christian Everdell <[REDACTED]>; BOBBI C STERNHEIM <[REDACTED]>; Jeff Pagliuca <[REDACTED]>; Laura Menninger <[REDACTED]>
Cc: [REDACTED]
Subject: RE: Draft joint proposed request to charge

Hi Chris,

I think the answer is yes, but just to make sure: we’d file the Government’s proposal on Wednesday, you’d file whatever redline you like on November 3. It also occurs to us that, since your redline will presumably contain new proposals/objections to ours and would not include our views, we’d want to file a short reply on November 5 or 8.

We’d consent to that option and, if you like, would join your motion for that schedule.

Thanks,
[REDACTED]

From: Christian Everdell <[REDACTED]>
Sent: Sunday, October 24, 2021 12:35 PM
To: [REDACTED]; BOBBI C STERNHEIM <[REDACTED]>; Jeff Pagliuca <[REDACTED]>; Laura Menninger <[REDACTED]>
Cc: [REDACTED] (USANYS) <[REDACTED]>
Subject: [EXTERNAL] RE: Draft joint proposed request to charge

Hi [REDACTED] –

I just want to clarify the redline option. If we did the redline option, would you file the government’s RTC (without defense comment) on Oct. 27 and then we would file the joint RTC (i.e., our redline of your RTCs) on Nov. 3? And you would consent to that option?

Thanks,

Chris

From: [REDACTED]
Sent: Friday, October 22, 2021 2:30 PM
To: Christian Everdell <[REDACTED]>; BOBBI C STERNHEIM <[REDACTED]>; Jeff Pagliuca <[REDACTED]>; Laura Menninger <[REDACTED]>
Cc: [REDACTED]
Subject: RE: Draft joint proposed request to charge

Hi Chris,

We had another idea that might facilitate things. We know Judge Nathan asked for a joint RTC, but what about asking Judge Nathan to let us file separate ones? We would also be comfortable setting a deadline for the defense RTC (or a defense redline of ours) on November 3.

If you were to make a request to file separate RTCs, with your deadline on November 3, we would join that request.

Thanks,
[REDACTED]

EFTA00025038

From: Christian Everdell <[REDACTED]>
Sent: Wednesday, October 20, 2021 4:07 PM
To: [REDACTED]; BOBBI C STERNHEIM <[REDACTED]>; Jeff Pagliuca <[REDACTED]>; Laura Menninger <[REDACTED]>
Cc: [REDACTED]
Subject: [EXTERNAL] RE: Draft joint proposed request to charge

Hi [REDACTED] –

Given all of the other things we have going on this week, the defense would like a little more time to submit the joint requests to charge. We plan to ask the Court for an extension until Monday, Nov. 1. Does the government consent to that request?

Thanks,

Chris

From: [REDACTED]
Sent: Wednesday, October 20, 2021 12:30 PM
To: Christian Everdell <[REDACTED]>; BOBBI C STERNHEIM <[REDACTED]>; Jeff Pagliuca <[REDACTED]>; Laura Menninger <[REDACTED]>
Cc: [REDACTED]
Subject: Draft joint proposed request to charge

Counsel,

Attached please find a draft joint proposed request to charge. Since this is due to the Court on Wednesday, October 27, please send us your comments by Sunday, October 24. Please also send us your comments, including any additional proposed jury instructions, as a redline to this document.

Thanks,
[REDACTED]

[REDACTED]
Assistant United States Attorney
Southern District of New York
[REDACTED]
[REDACTED]
[REDACTED]

EFTA00025039

View Original PDF

EFTA00025037.pdf

Processing Document...

Extraction Summary

Document Information

People (6)

Organizations (2)

Timeline (2 events)

Locations (1)

Relationships (2)

Key Quotes (4)

Full Extracted Text

Discussion 0