EFTA00021937.pdf
61.9 KB
Extraction Summary
8
People
3
Organizations
1
Locations
3
Events
2
Relationships
4
Quotes
Document Information
Type:
Email / legal correspondence
File Size:
61.9 KB
Summary
An email from an Assistant U.S. Attorney in the Southern District of New York to Ghislaine Maxwell's defense team (Everdell, Cohen, Pagliuca, Menninger) dated July 27, 2020. The prosecution requests a 'meet and confer' to discuss a protective order, specifically challenging the defense's desire to name victims in public filings rather than using pseudonyms. The email also requests a 1 terabyte hard drive to facilitate the production of discovery materials.
People (8)
| Name | Role | Context |
|---|---|---|
| Christian Everdell | Recipient / Defense Counsel |
Addressee of the email regarding US v. Maxwell
|
| Mark S. Cohen | CC / Defense Counsel |
Copied on the email
|
| Jeff Pagliuca | CC / Defense Counsel |
Copied on the email
|
| Laura Menninger | CC / Defense Counsel |
Copied on the email
|
| Ghislaine Maxwell | Defendant |
Subject of the case US v. Maxwell; mentioned regarding naming of victims
|
| Jeffrey Epstein | Deceased / Associated Figure |
Mentioned in context of victims self-identifying as victims of Epstein or Maxwell
|
| Alison J. Nathan | Judge |
Implied by case citation initials (AJN)
|
| Redacted Sender | Assistant U.S. Attorney |
Sender of the email representing the Government
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| U.S. Attorney's Office |
Sender's organization
|
|
| Southern District of New York |
Jurisdiction of the sender
|
|
| Federal Court |
Referenced via 'Court's Order'
|
Timeline (3 events)
Locations (1)
| Location | Context |
|---|---|
|
Location of the U.S. Attorney's Office
|
Relationships (2)
Email discusses victims of 'Jeffrey Epstein or Ghislaine Maxwell'
Everdell is the recipient of the email addressed to defense counsel for Maxwell
Key Quotes (4)
"Whether you are aware of any case in any federal district in which a protective order was entered in a criminal case that prevented the Government from showing its own documents to prospective witnesses or their counsel without requiring restrictions upon those witnesses and their counsel"Source
EFTA00021937.pdf
Quote #1
"Whether you are able to describe any expected reason why it would be necessary or useful for the defendant to reference by name — rather than by pseudonym or other anonymized identifier — any victim in a public statement or publicly-docketed filing"Source
EFTA00021937.pdf
Quote #2
"without conceding any right of the defendant to name any individual who has self-identified as a victim of Jeffrey Epstein or Ghislaine Maxwell at any time"Source
EFTA00021937.pdf
Quote #3
"please mail, or otherwise have delivered, a 1 terabyte hard drive for purposes of the Government’s discovery production."Source
EFTA00021937.pdf
Quote #4
Full Extracted Text
Complete text extracted from the document (2,484 characters)
From: [Redacted]" <[Redacted]>
To: Christian Everdell <[Redacted]>
Cc: "Mark S. Cohen" <[Redacted]>, Jeff Pagliuca <[Redacted]>, 'Laura
Menninger' <[Redacted]>, "[Redacted])" <[Redacted]>
Subject: RE: United States v. Maxwell, 20 Cr. 330 (AJN)
Date: Mon, 27 Jul 2020 20:43:15 +0000
To: Christian Everdell <[Redacted]>
Cc: "Mark S. Cohen" <[Redacted]>, Jeff Pagliuca <[Redacted]>, 'Laura
Menninger' <[Redacted]>, "[Redacted])" <[Redacted]>
Subject: RE: United States v. Maxwell, 20 Cr. 330 (AJN)
Date: Mon, 27 Jul 2020 20:43:15 +0000
[Redacted]
Pursuant to the Court’s Order of this afternoon, we write to schedule a telephonic meet and confer on issues relating to a
protective order in the above-captioned case. Please let us know what time you are available today between 5:00 p.m.
and 8:00 p.m., or tomorrow between 9:00 a.m. and 1:00 p.m. In particular, it would be helpful to get the defendant’s
current position on the following:
protective order in the above-captioned case. Please let us know what time you are available today between 5:00 p.m.
and 8:00 p.m., or tomorrow between 9:00 a.m. and 1:00 p.m. In particular, it would be helpful to get the defendant’s
current position on the following:
- Whether you are aware of any case in any federal district in which a protective order was entered in a criminal
case that prevented the Government from showing its own documents to prospective witnesses or their counsel
without requiring restrictions upon those witnesses and their counsel;
case that prevented the Government from showing its own documents to prospective witnesses or their counsel
without requiring restrictions upon those witnesses and their counsel;
- Whether you are able to describe any expected reason why it would be necessary or useful for the defendant to
reference by name — rather than by pseudonym or other anonymized identifier — any victim in a public statement
or publicly-docketed filing (and rather than by sealed filing, if such named identification is necessary), such that
the Government may consider whether it can formulate language to address any such concerns, without
conceding any right of the defendant to name any individual who has self-identified as a victim of Jeffrey Epstein
or Ghislaine Maxwell at any time; and
reference by name — rather than by pseudonym or other anonymized identifier — any victim in a public statement
or publicly-docketed filing (and rather than by sealed filing, if such named identification is necessary), such that
the Government may consider whether it can formulate language to address any such concerns, without
conceding any right of the defendant to name any individual who has self-identified as a victim of Jeffrey Epstein
or Ghislaine Maxwell at any time; and
- Whether the defense is willing to itself propose any language to address the Government’s concerns in relation
to the issue described immediately above, regarding the defendant’s desire to be able to reference by name any
victim in a public statement or publicly-docketed filing, without conceding that any such right exists.
to the issue described immediately above, regarding the defendant’s desire to be able to reference by name any
victim in a public statement or publicly-docketed filing, without conceding that any such right exists.
Additionally, also relating to the production of discovery, please mail, or otherwise have delivered, a 1 terabyte hard drive
for purposes of the Government’s discovery production. While we are in the process of determining the size of an initial
production, and the size may total substantially less than 1 terabyte, that will ensure our ability to make a robust initial
production and should be suitable for subsequent productions as well. That can be sent to my attention at our Office.
for purposes of the Government’s discovery production. While we are in the process of determining the size of an initial
production, and the size may total substantially less than 1 terabyte, that will ensure our ability to make a robust initial
production and should be suitable for subsequent productions as well. That can be sent to my attention at our Office.
Regards,
[Redacted]
Assistant U.S. Attorney
Southern District of New York
Assistant U.S. Attorney
Southern District of New York
EFTA00021937
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