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EFTA00014655.pdf

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Extraction Summary

5
People
4
Organizations
4
Locations
2
Events
1
Relationships
3
Quotes

Document Information

Type: Email chain / legal correspondence
File Size: 89.6 KB
Summary

This document contains an email chain from November 20, 2021, between the U.S. Attorney's Office (SDNY) and defense counsel for Ghislaine Maxwell (Laura Menninger and Jeff Pagliuca). The correspondence concerns the logistics of discovery production, including the shipment of hard drives containing witness materials to counsel in Colorado and to Maxwell at the MDC, as well as clarifications regarding Bates numbering errors. The emails provide specific FedEx tracking numbers for the shipments.

People (5)

Name Role Context
Laura Menninger Defense Attorney
Recipient of discovery materials; inquiring about missing Bates numbers.
Jeff Pagliuca Defense Attorney
Recipient on email chain.
Ghislaine Maxwell Defendant
Referred to as 'your client' and 'Ms. Maxwell'; currently at MDC; receiving hard drive of discovery materials.
Chris Unknown (likely courier or staff)
Hard drive left for pickup under his name.
Redacted (USANYS) Assistant United States Attorney
Sender of discovery materials and emails.

Organizations (4)

Name Type Context
USANYS
U.S. Attorney's Office for the Southern District of New York (SDNY)
USAfx
File sharing platform used for discovery production.
FedEx
Courier service used to ship hard drives.
MDC
Metropolitan Detention Center; where Ms. Maxwell is detained.

Timeline (2 events)

2021-11-20
Hard drive with discovery materials sent via FedEx to Laura Menninger's office in Colorado.
Colorado
USANYS Laura Menninger
View
2021-11-20
Hard drive with discovery materials sent via FedEx to Ms. Maxwell at the MDC.
MDC
USANYS Ghislaine Maxwell
View

Locations (4)

Location Context
Colorado
Location of Laura Menninger's office.
MDC
Detention center where Maxwell is located.
New York, New York
Location of U.S. Attorney's Office.
Southern District of New York
Jurisdiction of the case.

Relationships (1)

Laura Menninger → Attorney-Client → Ghislaine Maxwell
Email refers to Maxwell as 'your client' when addressing Menninger.

Key Quotes (3)

"The letter inadvertently listed SDNY_GM_02774195 instead of SDNY_GM_02774105."
Source
EFTA00014655.pdf
Quote #1
"We have also sent a hard drive to your client at the MDC via FedEx."
Source
EFTA00014655.pdf
Quote #2
"We will also produce the testifying witness and non-testifying witness material and exhibits via USAfx."
Source
EFTA00014655.pdf
Quote #3

Full Extracted Text

Complete text extracted from the document (3,100 characters)

From: [REDACTED] (USANYS) <[REDACTED]>
To: Laura Menninger <[REDACTED]>, [REDACTED] <[REDACTED]>, Jeff Pagliuca <[REDACTED]>
Cc: [REDACTED] (USANYS) <[REDACTED]>, [REDACTED] <[REDACTED]>, [REDACTED] (USANYS) [Contractor] <[REDACTED]>
Subject: RE: US v. Maxwell, 20 Cr. 330 (AJN)
Date: Sat, 20 Nov 2021 21:52:41 +0000
Attachments: 2021.11.20_Maxwell_Discovery_Letter_-_Corrected.pdf
Laura,
I’m attaching a corrected cover letter for the discovery production. The letter inadvertently listed SDNY_GM_02774195 instead of SDNY_GM_02774105. We have sent a hard drive to your office in Colorado (the FedEx tracking number is 8166 1429 9380). We have also sent a hard drive to your client at the MDC via FedEx. The tracking number for the drive is 8166 1445 3318, and the tracking number for the password is 8166 1445 3307. We are leaving a hard drive at our office for pickup under Chris’s name.
We have uploaded the production except for SDNY_GM_02774100-SDNY_GM_02774104 to USAfx. We could not upload SDNY_GM_02774100-SDNY_GM_02774104 due to size limitations. The materials have been added to the same USAfx production folder [REDACTED] shared with you earlier today.
Thanks,
[REDACTED]
From: Laura Menninger <[REDACTED]>
Sent: Saturday, November 20, 2021 4:17 PM
To: [REDACTED] (USANYS) <[REDACTED]>; [REDACTED]; [REDACTED]; Jeff Pagliuca <[REDACTED]>
Cc: [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] (USANYS) [Contractor] <[REDACTED]>
Subject: [EXTERNAL] RE: US v. Maxwell, 20 Cr. 330 (AJN)
[REDACTED]:
A second question for you – the discovery letter appears to skip bates numbers 2774105-2774194.
Can you please confirm whether that was intentional or let us know what additional documents are contained in that range?
Thank you,
Laura
From: [REDACTED] (USANYS) <[REDACTED]>
Sent: Saturday, November 20, 2021 12:53 PM
To: [REDACTED]; [REDACTED]; Laura Menninger <[REDACTED]>; Jeff Pagliuca <[REDACTED]>
Cc: [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] (USANYS) [Contractor]
<[REDACTED]>
Subject: US v. Maxwell, 20 Cr. 330 (AJN)
Counsel,
We have an additional discovery production ready to send to you. Attached please find the accompanying cover letter. That will be produced on a hard drive to you. In addition, a supplemental production of testifying witness and non-testifying witness material and exhibits are also ready to send to you. Attached please find the accompanying cover letter and indices. Those materials will be on the hard drive as well. We will also produce the testifying witness and non-testifying witness material and exhibits via USAfx.
Please let us know if you would like to pick up the drive today or if you would like us to FedEx it (and if so, to where).
Please let us know if you would like us to send today via FedEx a hard drive with these materials to Ms. Maxwell at the MDC or bring the hard drive to court on Tuesday.
Thanks,
[REDACTED]
[REDACTED]
Assistant United States Attorney
United States Attorney’s Office
Southern District of New York
[REDACTED]
New York, New York 10007
Tel: [REDACTED]
EFTA00014655
EFTA00014656
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