EFTA00030084.pdf
329 KB
Extraction Summary
5
People
4
Organizations
5
Locations
7
Events
5
Relationships
9
Quotes
Document Information
Type:
Email chain
File Size:
329 KB
Summary
This document is an email chain from March 2021 concerning discovery and evidence review in the US v. Maxwell case. The correspondence primarily involves Laura Menninger (defense counsel) and an Assistant United States Attorney, discussing the availability and indexing of highly confidential physical evidence and images held by the FBI. Delays in providing answers and access to evidence are noted, with discussions around FBI team availability and the completeness of existing evidence inventories.
People (5)
| Name | Role | Context |
|---|---|---|
| Laura Menninger | Partner |
Sender/Recipient of emails, from Haddon, Morgan & Foreman, P.C.
|
| Jeff Pagliuca | CC Recipient |
Email address jpagliuca@hmflaw.com
|
| Christian R Everdell | CC Recipient |
From Cohen & Gresser LLP, email address ceverdell@cohengresser.com
|
| BOBBI C STERNHEIM | CC Recipient |
Email address bcsternheim@mac.com
|
| Jeffrey Epstein | Subject of FBI searches |
His residences in NY and USVI were searched in 2019
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| Haddon, Morgan & Foreman, P.C. |
Law firm of Laura Menninger and Jeff Pagliuca
|
|
| Cohen & Gresser LLP |
Law firm of Christian R Everdell
|
|
| Southern District of New York |
Office of Assistant United States Attorney
|
|
| FBI |
Investigative agency involved in evidence custody and searches
|
Timeline (7 events)
2019
FBI searches of Jeffrey Epstein's residences in New York and U.S Virgin Islands
New York, NY; U.S Virgin Islands
2021-03-09
Call scheduled to discuss requests in letter and attached index of physical items from FBI-Miami office
Laura Menninger
[REDACTED] (Assistant US Attorney)
2021-05-18
Date for client to review highly confidential images at 500 Pearl Street
500 Pearl Street
client
FBI team
Locations (5)
| Location | Context |
|---|---|
|
Address for Assistant United States Attorney, New York, NY
|
|
|
Location of FBI searches and Assistant United States Attorney office
|
|
|
Location of FBI searches of Jeffrey Epstein's residences
|
|
|
Address for Haddon, Morgan & Foreman, P.C.
|
|
|
Location where client can review highly confidential images
|
Relationships (5)
Both are from Haddon, Morgan & Foreman, P.C. and are CC'd on each other's emails.
CC'd on emails regarding the US v. Maxwell case.
CC'd on emails regarding the US v. Maxwell case.
Laura Menninger
→
legal counsel/prosecution correspondence
→
[REDACTED] (Assistant United States Attorney)
Primary sender/recipient of emails discussing evidence and discovery in US v. Maxwell.
FBI seized evidence from Epstein's residences, holds evidence in custody.
Key Quotes (9)
"I expect to be able to answer all of your questions about the evidence review by tomorrow."Source
EFTA00030084.pdf
Quote #1
"Now that the FBI team is back, when do you expect to have answers to all of the questions posed?"Source
EFTA00030084.pdf
Quote #2
"At a minimum, it would not seem to take too much time to know when someone can open the FBI vault and allow the attorneys to make an initial view of the evidence."Source
EFTA00030084.pdf
Quote #3
"I understand the FBI did not prepare an inventory of their evidence when they seized it from NY and LSI, so I don't think we need to wait for them to now prepare an inventory before we start reviewing evidence."Source
EFTA00030084.pdf
Quote #4
"The FBI team on this case has been out of the office this week and will not be able to answer all of the questions you asked during our Wednesday call until they are back in the office next week."Source
EFTA00030084.pdf
Quote #5
"My understanding is that the FBI is able to provide at least one laptop containing those highly confidential images in time for such a review to take place on Thursday 5/18"Source
EFTA00030084.pdf
Quote #6
"That is the only excel spreadsheet indexing physical evidence that we have produced in discovery. That spreadsheet does not include every physical item currently in the FBI's custody related to this case."Source
EFTA00030084.pdf
Quote #7
"As a courtesy, I have asked the FBI whether it would be possible to provide us with a similar excel index reflecting the physical evidence seized by the FBI's New York Office, though it may take some time to compile such an index."Source
EFTA00030084.pdf
Quote #8
"In advance of our call tomorrow, I wanted to send a copy of the attached index of physical items in FBI custody from the FBI-Miami office, which we previously produced to you as part of our August 21, 2020 discovery production."Source
EFTA00030084.pdf
Quote #9
Full Extracted Text
Complete text extracted from the document (9,831 characters)
From: [REDACTED]
To: Laura Menninger , [REDACTED]
(USANYS)
Cc: Jeff Pagliuca , Christian R Everdell - Cohen & Gresser LLP
, 'BOBBI C STERNHEIM'
Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Date: Mon, 15 Mar 2021 21:59:40 +0000
Inline-Images: image001.jpg
To: Laura Menninger , [REDACTED]
(USANYS)
Cc: Jeff Pagliuca , Christian R Everdell - Cohen & Gresser LLP
, 'BOBBI C STERNHEIM'
Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Date: Mon, 15 Mar 2021 21:59:40 +0000
Inline-Images: image001.jpg
Laura,
I expect to be able to answer all of your questions about the evidence review by tomorrow.
We have been looking into the discovery request you made last week, and we hope to have a response ready to provide
to you by next week.
to you by next week.
Best,
[REDACTED]
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
[REDACTED]
From: Laura Menninger
Sent: Monday, March 15, 2021 3:01 PM
To: [REDACTED]
(USANYS)
Cc: Jeff Pagliuca , Christian R Everdell - Cohen & Gresser LLP
, 'BOBBI C STERNHEIM'
Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Sent: Monday, March 15, 2021 3:01 PM
To: [REDACTED]
(USANYS)
Cc: Jeff Pagliuca , Christian R Everdell - Cohen & Gresser LLP
, 'BOBBI C STERNHEIM'
Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
[REDACTED]
Now that the FBI team is back, when do you expect to have answers to all of the questions posed? If I had an idea of
when you would have answers, it could help me answer your question.
when you would have answers, it could help me answer your question.
At a minimum, it would not seem to take too much time to know when someone can open the FBI vault and allow the
attorneys to make an initial view of the evidence. Also, I understand the FBI did not prepare an inventory of their
evidence when they seized it from NY and LSI, so I don't think we need to wait for them to now prepare an inventory
before we start reviewing evidence.
attorneys to make an initial view of the evidence. Also, I understand the FBI did not prepare an inventory of their
evidence when they seized it from NY and LSI, so I don't think we need to wait for them to now prepare an inventory
before we start reviewing evidence.
Also, when do you believe you will have a response regarding the discovery I requested last Monday?
EFTA00030084
Thanks,
Laura
Laura
LAURA A. MENNINGER | Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue | Denver, CO 80203
+1 303 831 7364 (Office)
lmenninger@hmflaw.com
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue | Denver, CO 80203
+1 303 831 7364 (Office)
lmenninger@hmflaw.com
From: [REDACTED]
Sent: Friday, March 12, 2021 11:44 AM
To: Laura Menninger
[REDACTED]
(USANYS)
Cc: Jeff Pagliuca , Christian R Everdell - Cohen & Gresser LLP
, 'BOBBI C STERNHEIM'
Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Sent: Friday, March 12, 2021 11:44 AM
To: Laura Menninger
[REDACTED]
(USANYS)
Cc: Jeff Pagliuca , Christian R Everdell - Cohen & Gresser LLP
, 'BOBBI C STERNHEIM'
Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Counsel,
The FBI team on this case has been out of the office this week and will not be able to answer all of the questions you
asked during our Wednesday call until they are back in the office next week. Please let me know if you would like to wait
until all of those questions can be answered to schedule a day for your client to be brought to 500 Pearl Street to review
the highly confidential images. My understanding is that the FBI is able to provide at least one laptop containing those
highly confidential images in time for such a review to take place on Thursday 5/18, but I may not have the answers to all
of your questions about those images before that date, and I do not know whether you will also be able to visit the
evidence vault that same week.
asked during our Wednesday call until they are back in the office next week. Please let me know if you would like to wait
until all of those questions can be answered to schedule a day for your client to be brought to 500 Pearl Street to review
the highly confidential images. My understanding is that the FBI is able to provide at least one laptop containing those
highly confidential images in time for such a review to take place on Thursday 5/18, but I may not have the answers to all
of your questions about those images before that date, and I do not know whether you will also be able to visit the
evidence vault that same week.
Please let me know how you would like to proceed. I will reach back out once I have answers to your questions.
Thank you,
[REDACTED]
[REDACTED]
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
[REDACTED]
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
[REDACTED]
From: [REDACTED]
Sent: Tuesday, March 9, 2021 4:56 PM
To: Laura Menninger
[REDACTED]
(USANYS)
Cc: Jeff Pagliuca , Christian R Everdell - Cohen & Gresser LLP
, 'BOBBI C STERNHEIM'
Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Sent: Tuesday, March 9, 2021 4:56 PM
To: Laura Menninger
[REDACTED]
(USANYS)
Cc: Jeff Pagliuca , Christian R Everdell - Cohen & Gresser LLP
, 'BOBBI C STERNHEIM'
Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
That is the only excel spreadsheet indexing physical evidence that we have produced in discovery. That spreadsheet does
not include every physical item currently in the FBI's custody related to this case. For example, the August 20, 2020
not include every physical item currently in the FBI's custody related to this case. For example, the August 20, 2020
EFTA00030085
discovery production also included search warrant returns listing the physical items seized by the FBI's New York Office
during the 2019 searches of Jeffrey Epstein's residences in New York and the U.S Virgin Islands (see Bates range
SDNY_GM_00166007-SDNY_GM_00166043), but they are not contained in a spreadsheet.
during the 2019 searches of Jeffrey Epstein's residences in New York and the U.S Virgin Islands (see Bates range
SDNY_GM_00166007-SDNY_GM_00166043), but they are not contained in a spreadsheet.
As a courtesy, I have asked the FBI whether it would be possible to provide us with a similar excel index reflecting the
physical evidence seized by the FBI's New York Office, though it may take some time to compile such an index.
physical evidence seized by the FBI's New York Office, though it may take some time to compile such an index.
Best,
[REDACTED]
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
[REDACTED]
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
[REDACTED]
From: Laura Menninger
Sent: Tuesday, March 9, 2021 3:44 PM
To: [REDACTED]
[REDACTED]
(USANYS)
Cc: Jeff Pagliuca , Christian R Everdell - Cohen & Gresser LLP
, 'BOBBI C STERNHEIM'
Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Sent: Tuesday, March 9, 2021 3:44 PM
To: [REDACTED]
[REDACTED]
(USANYS)
Cc: Jeff Pagliuca , Christian R Everdell - Cohen & Gresser LLP
, 'BOBBI C STERNHEIM'
Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Thank you. Is that the only index of physical evidence available?
LAURA A. MENNINGER | Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue | Denver, CO 80203
+1 303 831 7364 (Office)
lmenninger@hmflaw.com
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue | Denver, CO 80203
+1 303 831 7364 (Office)
lmenninger@hmflaw.com
From: [REDACTED]
Sent: Tuesday, March 9, 2021 1:38 PM
To: Laura Menninger
[REDACTED]
(USANYS)
Cc: Jeff Pagliuca , Christian R Everdell - Cohen & Gresser LLP
, 'BOBBI C STERNHEIM'
Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Sent: Tuesday, March 9, 2021 1:38 PM
To: Laura Menninger
[REDACTED]
(USANYS)
Cc: Jeff Pagliuca , Christian R Everdell - Cohen & Gresser LLP
, 'BOBBI C STERNHEIM'
Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Counsel,
In advance of our call tomorrow, I wanted to send a copy of the attached index of physical items in FBI custody from the
FBI-Miami office, which we previously produced to you as part of our August 21, 2020 discovery production. Also
included in that August 21, 2020 production were scans of numerous items listed on the index. Those scans can be found
within Bates range SDNY_GM_00172218-SDNY_GM_00173007. It may be useful to reference some of those items during
our conversation tomorrow, so I wanted to make sure you were aware of them.
FBI-Miami office, which we previously produced to you as part of our August 21, 2020 discovery production. Also
included in that August 21, 2020 production were scans of numerous items listed on the index. Those scans can be found
within Bates range SDNY_GM_00172218-SDNY_GM_00173007. It may be useful to reference some of those items during
our conversation tomorrow, so I wanted to make sure you were aware of them.
Best,
EFTA00030086
[REDACTED]
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
[REDACTED]
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
[REDACTED]
From: [REDACTED]
Sent: Tuesday, March 9, 2021 2:03 PM
To: 'Laura Menninger'
[REDACTED]
(USANYS)
Cc: Jeff Pagliuca , Christian R Everdell - Cohen & Gresser LLP
, 'BOBBI C STERNHEIM'
Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Sent: Tuesday, March 9, 2021 2:03 PM
To: 'Laura Menninger'
[REDACTED]
(USANYS)
Cc: Jeff Pagliuca , Christian R Everdell - Cohen & Gresser LLP
, 'BOBBI C STERNHEIM'
Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Yes, that works for us, thank you very much. We can use the below dial-in:
Dial-in: [REDACTED]
Code: [REDACTED]
Code: [REDACTED]
Best,
[REDACTED]
[REDACTED]
From: Laura Menninger
Sent: Tuesday, March 9, 2021 11:19 AM
To: [REDACTED]
[REDACTED]
(USANYS)
Cc: Jeff Pagliuca , Christian R Everdell - Cohen & Gresser LLP
, 'BOBBI C STERNHEIM'
Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Sent: Tuesday, March 9, 2021 11:19 AM
To: [REDACTED]
[REDACTED]
(USANYS)
Cc: Jeff Pagliuca , Christian R Everdell - Cohen & Gresser LLP
, 'BOBBI C STERNHEIM'
Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Good morning.
We are free at 1:30 p.m. ET / 11:30 a.m. MST tomorrow. Would that work? We are generally free thereafter, so please
suggest another later time if not.
suggest another later time if not.
Thank you,
Laura
Laura
LAURA A. MENNINGER | Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue | Denver, CO 80203
+1 303 831 7364 (Office)
lmenninger@hmflaw.com
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue | Denver, CO 80203
+1 303 831 7364 (Office)
lmenninger@hmflaw.com
From: [REDACTED]
Sent: Tuesday, March 9, 2021 8:36 AM
To: Laura Menninger
[REDACTED]
Sent: Tuesday, March 9, 2021 8:36 AM
To: Laura Menninger
[REDACTED]
EFTA00030087
(USANYS)
Cc: Jeff Pagliuca , Christian R Everdell - Cohen & Gresser LLP
, 'BOBBI C STERNHEIM'
Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Cc: Jeff Pagliuca , Christian R Everdell - Cohen & Gresser LLP
, 'BOBBI C STERNHEIM'
Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Good morning.
It would be helpful to have a call to discuss the requests contained in this letter. Are there times tomorrow when you
would be available to speak, please?
would be available to speak, please?
Thank you,
[REDACTED]
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
[REDACTED]
[REDACTED]
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
[REDACTED]
From: Laura Menninger
Sent: Monday, March 8, 2021 2:03 PM
To: [REDACTED]
[REDACTED]
(USANYS)
Cc: Jeff Pagliuca , Christian R Everdell - Cohen & Gresser LLP
, 'BOBBI C STERNHEIM'
Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Sent: Monday, March 8, 2021 2:03 PM
To: [REDACTED]
[REDACTED]
(USANYS)
Cc: Jeff Pagliuca , Christian R Everdell - Cohen & Gresser LLP
, 'BOBBI C STERNHEIM'
Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Counsel –
Please see attached correspondence.
-Laura
LAURA A. MENNINGER | Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue | Denver, CO 80203
+1 303 831 7364 (Office)
lmenninger@hmflaw.com
www.hmflaw.com
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue | Denver, CO 80203
+1 303 831 7364 (Office)
lmenninger@hmflaw.com
www.hmflaw.com
CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages
attached to it may contain information that is confidential or legally privileged. If you are not the intended
recipient, or a person responsible for delivering it to the intended recipient, you are hereby notified that you
must not read this transmission and that any disclosure, copying, distribution or use of any of the
information contained in or attached to this transmission is STRICTLY PROHIBITED. If you have received this
attached to it may contain information that is confidential or legally privileged. If you are not the intended
recipient, or a person responsible for delivering it to the intended recipient, you are hereby notified that you
must not read this transmission and that any disclosure, copying, distribution or use of any of the
information contained in or attached to this transmission is STRICTLY PROHIBITED. If you have received this
EFTA00030088
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