EFTA00031202.pdf

113 KB

Extraction Summary

6
People
4
Organizations
2
Locations
3
Events
2
Relationships
3
Quotes

Document Information

Type: Email chain
File Size: 113 KB
Summary

This document is an email chain from October 14-15, 2021, among US Attorney's Office (USANYS) staff coordinating a response to a letter filed by Ghislaine Maxwell's defense attorney, Bobbi Sternheim. The emails reveal urgent internal coordination to meet a 5 PM deadline set by Judge Nathan, discussions about reviewing the draft with the MDC/BOP, and strategic decisions regarding how to address specific points raised by the defense, specifically regarding legal mail and the volume of discovery materials.

People (6)

Name Role Context
Bobbi C. Sternheim Defense Attorney
Sender of the original email with the ECF filing attachment.
Judge Nathan Judge
Referenced as having ordered a response by 5 pm and setting deadlines.
Christian Everdell CC Recipient
Copied on the email from Bobbi Sternheim; likely defense team.
Laura Menninger CC Recipient
Copied on the email from Bobbi Sternheim; likely defense team.
Jeff Pagliuca CC Recipient
Copied on the email from Bobbi Sternheim; likely defense team.
Unknown USANYS Staff Government Prosecutors/Staff
Multiple redacted senders and recipients within the US Attorney's Office discussing the response.

Organizations (4)

Name Type Context
USANYS
US Attorney's Office for the Southern District of New York (senders of internal emails).
MDC
Metropolitan Detention Center (location referenced regarding review of a letter and legal mail).
BOP
Bureau of Prisons (contacted to set up a call).
Law Offices of Bobbi C. Sternheim
Firm representing the defendant.

Timeline (3 events)

2021-10-14
Bobbi Sternheim files a letter/ECF filing.
New York
Bobbi Sternheim
2021-10-15
Judge Nathan orders US Government to respond to Sternheim letter by 5 PM.
Court
2021-10-15
USANYS coordinates with MDC/BOP to review draft response letter.
MDC
USANYS MDC Staff BOP

Locations (2)

Location Context
Address for Bobbi C. Sternheim.
MDC
Detention center where personnel need to review the draft letter.

Relationships (2)

Bobbi C. Sternheim Legal Counsel Ghislaine Maxwell
Filing letters on behalf of defense in U.S. v. Maxwell
Judge Nathan Judicial Oversight USANYS
Judge Nathan ordering the USANYS to respond by a specific deadline.

Key Quotes (3)

"Judge Nathan just ordered us to respond to this letter as soon as possible but no later than 5 pm today."
Source
EFTA00031202.pdf
Quote #1
"We've really got to talk to Nathan about these deadlines!"
Source
EFTA00031202.pdf
Quote #2
"We haven't engaged with the defense's footnote 1 about the volume of the materials delivered because that is a little more complicated and we want to make sure any representations are fully accurate"
Source
EFTA00031202.pdf
Quote #3

Full Extracted Text

Complete text extracted from the document (3,727 characters)

From: [Redacted] (USANYS)" <[Redacted]>
To: [Redacted] (USANYS)" <[Redacted]>, "[Redacted] (USANYS)"
Cc: [Redacted]
Subject: RE: [EXTERNAL] U.S. v. Maxwell S2 20 Cr. 330 (AJN)
Date: Fri, 15 Oct 2021 19:44:58 +0000
Attachments: 2021-10-15_GM_letter_re_MDC_legal_mail_Final.docx
[Redacted] and [Redacted] signed off on the letter. Attaching what we plan to file.
From: [Redacted] (USANYS) <[Redacted]>
Sent: Friday, October 15, 2021 2:04 PM
To: [Redacted] (USANYS) <[Redacted]>
Cc: [Redacted] (USANYS) <[Redacted]>; [Redacted] <[Redacted]>; [Redacted] <[Redacted]>
Subject: Re: [EXTERNAL] U.S. v. Maxwell S2 20 Cr. 330 (AJN)
Ah-I see the highlights now. Agree.
Sent from my iPhone
On Oct 15, 2021, at 1:49 PM, [Redacted] (USANYS) <[Redacted]> wrote:
I think this is good but would delete the highlighted sentences. I agree with not engaging on footnote.
Sent from my iPhone
On Oct 15, 2021, at 1:29 PM, [Redacted] (USANYS) <[Redacted]> wrote:
[Redacted], [Redacted],
Attached is a draft response due today at 5 pm. We still need to send this letter to [Redacted] and [Redacted] at the MDC to review for accuracy. Do you think you will be able to review shortly or should I send them this draft simultaneously? We highlighted some language for your consideration about Judge Nathan's deadlines, happy to discuss. We haven't engaged with the defense's footnote 1 about the volume of the materials delivered because that is a little more complicated and we want to make sure any representations are fully accurate, but happy to discuss.
Thanks,
[Redacted]
From: [Redacted] (USANYS) <[Redacted]>
Sent: Friday, October 15, 2021 10:30 AM
To: [Redacted] <[Redacted]>; [Redacted] (USANYS) <[Redacted]>; [Redacted] (USANYS) <[Redacted]>
Cc: [Redacted] <[Redacted]>; [Redacted] <[Redacted]>
Subject: RE: [EXTERNAL] U.S. v. Maxwell S2 20 Cr. 330 (AJN)
Thanks. (We've really got to talk to Nathan about these deadlines!)
From: [Redacted]
Sent: Friday, October 15, 2021 10:30 AM
To: [Redacted] (USANYS) <[Redacted]>; [Redacted] (USANYS) <[Redacted]>; [Redacted] (USANYS) <[Redacted]>
Cc: [Redacted] <[Redacted]>; [Redacted] <[Redacted]>
Subject: RE: [EXTERNAL] U.S. v. Maxwell S2 20 Cr. 330 (AJN)
Hi [Redacted] / [Redacted],
Judge Nathan just ordered us to respond to this letter as soon as possible but no later than 5 pm today. We've reached out to BOP to set up a call.
Thanks,
[Redacted]
From: [Redacted] (USANYS) <[Redacted]>
Sent: Thursday, October 14, 2021 8:31 PM
To: [Redacted] (USANYS) <[Redacted]>; [Redacted] (USANYS) <[Redacted]>
Cc: [Redacted] <[Redacted]>; [Redacted] <[Redacted]>; [Redacted] <[Redacted]>
Subject: FW: [EXTERNAL] U.S. v. Maxwell S2 20 Cr. 330 (AJN)
FYI, letter filed by Bobbi Sternheim tonight.
From: BOBBI C STERNHEIM
Sent: Thursday, October 14, 2021 7:46 PM
To: [Redacted] <[Redacted]>; [Redacted] (USANYS) <[Redacted]>; [Redacted]
Cc: Christian Everdell <[Redacted]>; Laura Menninger <[Redacted]>; Jeff Pagliuca
Subject: [EXTERNAL] U.S. v. Maxwell S2 20 Cr. 330 (AJN)
Good evening-
Attached is a courtesy copy of this evening's ECF filing.
Bobbi
BOBBI C. STERNHEIM, ESQ.
[Redacted Address]
New York, NY 10007
[Redacted Phone Numbers]
This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim that may be confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and then delete this message. Thank you.
<2021-10-15 GM letter re MDC legal mail v2 [to chiefs].docx>
EFTA00031202
EFTA00031203
EFTA00031204

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