EFTA00032669.pdf
1.22 MB
Extraction Summary
7
People
6
Organizations
7
Locations
2
Events
2
Relationships
4
Quotes
Document Information
Type:
Legal correspondence / email chain
File Size:
1.22 MB
Summary
This document contains a chain of emails between Ghislaine Maxwell's defense team (Haddon, Morgan & Foreman; Cohen & Gresser) and the US Attorney's Office regarding the logistics of reviewing evidence for the case US v. Maxwell. The correspondence details disputes and arrangements for reviewing 'highly confidential' materials, including over 2,100 nude/partially nude images seized from Jeffrey Epstein's devices, as well as physical evidence stored at an FBI warehouse in the Bronx. Specific items discussed include massage tables, plaster busts of female torsos, a stuffed dog, cash held at Federal Plaza, and various electronic recording media.
People (7)
| Name | Role | Context |
|---|---|---|
| Laura Menninger | Defense Attorney |
Partner at Haddon, Morgan & Foreman, P.C.; representing Ghislaine Maxwell.
|
| Christian Everdell | Defense Attorney |
Lawyer at Cohen & Gresser LLP; representing Ghislaine Maxwell.
|
| Jeff Pagliuca | Defense Attorney |
Haddon, Morgan & Foreman, P.C.; representing Ghislaine Maxwell.
|
| Bobbi C. Sternheim | Defense Attorney |
Cc'd on correspondence.
|
| Ghislaine Maxwell | Defendant |
Referred to as 'Ms. Maxwell' or 'client'; subject of the evidence review.
|
| Jeffrey Epstein | Deceased |
Source of seized evidence (residences, devices).
|
| Assistant United States Attorney (Redacted) | Prosecutor |
Sender/Recipient from US Attorney's Office (USANYS).
|
Organizations (6)
| Name | Type | Context |
|---|---|---|
| US Attorney's Office, Southern District of New York (USANYS) |
Prosecution team.
|
|
| FBI (Federal Bureau of Investigation) |
Agency holding custody of evidence at Bronx warehouse and NY office.
|
|
| Haddon, Morgan & Foreman, P.C. |
Defense law firm.
|
|
| Cohen & Gresser LLP |
Defense law firm.
|
|
| MDC (Metropolitan Detention Center) |
Where Ghislaine Maxwell was being held.
|
|
| PBSO (Palm Beach Sheriff's Office) |
Source of some evidence (DVD-R discs).
|
Timeline (2 events)
2019
FBI searches of Jeffrey Epstein's residences (NY, Florida, Virgin Islands) resulting in seizure of devices and physical evidence.
NY, Florida, USVI
FBI
Jeffrey Epstein
2021-04-12
Scheduled evidence review at FBI Bronx Warehouse and 500 Pearl Street.
2350 Lafayette Ave, Bronx, NY and 500 Pearl St, NY
Defense Team
FBI Agents
AUSA
Locations (7)
| Location | Context |
|---|---|
|
Federal Courthouse in NY; location for evidence review and proffer rooms.
|
|
|
FBI Warehouse storing physical evidence.
|
|
|
US Attorney's Office address.
|
|
|
Location holding cash evidence.
|
|
|
Epstein's home where evidence was seized.
|
|
|
Epstein's home where evidence was seized.
|
|
|
Epstein's residence (Little St. James) mentioned regarding search warrant returns.
|
Relationships (2)
Menninger refers to Maxwell as 'our client' and discusses logistics for her to review evidence.
References to searches of Epstein's residences and seizure of his property.
Key Quotes (4)
"We would propose excluding the below items from production to 500 Pearl: ... massage tables ... plaster busts of female torsos and a stuffed dog."Source
EFTA00032669.pdf
Quote #1
"Approximately 2,100 electronic images and videos seized from Epstein's electronic devices... All such images have been designated Highly Confidential."Source
EFTA00032669.pdf
Quote #2
"I am suspicious that 'one original recording of an interview' is not truly only an 'electronic' file? I was practicing law in 2007 and do not recall 'electronic files' being the standard then."Source
EFTA00032669.pdf
Quote #3
"The FBI has seized dozens of electronic devices, including desktop computers, servers, and laptops, from Jeffrey Epstein's residences in 2019."Source
EFTA00032669.pdf
Quote #4
Full Extracted Text
Complete text extracted from the document (6,688 characters)
From: [REDACTED]
To: Christian Everdell , 'Laura Menninger' , '[REDACTED] (USANYS)'
Cc: Jeff Pagliuca , 'BOBBI C STERNHEIM'
Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Date: Thu, 08 Apr 2021 21:42:37 +0000
Inline-Images: image001.jpg
To: Christian Everdell , 'Laura Menninger' , '[REDACTED] (USANYS)'
Cc: Jeff Pagliuca , 'BOBBI C STERNHEIM'
Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Date: Thu, 08 Apr 2021 21:42:37 +0000
Inline-Images: image001.jpg
Great, thank you very much. Confirmed for 11am on April 12th. It can be a bit tricky to find the entrance to the warehouse, so please feel free to call my cellphone ([REDACTED]) when you arrive, and I can help direct you.
Best,
[REDACTED]
[REDACTED]
From: Christian Everdell
Sent: Thursday, April 8, 2021 5:22 PM
To: [REDACTED]; 'Laura Menninger' ; [REDACTED] (USANYS)
Cc: Jeff Pagliuca ; 'BOBBI C STERNHEIM'
Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Sent: Thursday, April 8, 2021 5:22 PM
To: [REDACTED]; 'Laura Menninger' ; [REDACTED] (USANYS)
Cc: Jeff Pagliuca ; 'BOBBI C STERNHEIM'
Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Thanks, [REDACTED] 11am is fine. I don't think we will need more time. If for some reason we need to go back later in the week, we can arrange for another trip to finish up.
From: [REDACTED] (USANYS)
Sent: Thursday, April 08, 2021 5:19 PM
To: Christian Everdell; 'Laura Menninger'; [REDACTED]; [REDACTED] (USANYS)
Cc: Jeff Pagliuca; 'BOBBI C STERNHEIM'
Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Sent: Thursday, April 08, 2021 5:19 PM
To: Christian Everdell; 'Laura Menninger'; [REDACTED]; [REDACTED] (USANYS)
Cc: Jeff Pagliuca; 'BOBBI C STERNHEIM'
Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Chris,
I am going to be tied up for a bit the morning on the 12th. Would it work on your end to meet at the warehouse at 11am, please? The warehouse will be open until 4:30pm, though I'm told I can request additional time in advance if you think the review will take more than 5 ½ hours.
Also, I am working on gathering information in response to Laura's email and expect to be able to respond to it later this evening.
I am going to be tied up for a bit the morning on the 12th. Would it work on your end to meet at the warehouse at 11am, please? The warehouse will be open until 4:30pm, though I'm told I can request additional time in advance if you think the review will take more than 5 ½ hours.
Also, I am working on gathering information in response to Laura's email and expect to be able to respond to it later this evening.
Thank you,
[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
From: Christian Everdell
Sent: Thursday, April 8, 2021 5:06 PM
To: 'Laura Menninger' ; [REDACTED] (USANYS)
Cc: Jeff Pagliuca ; 'BOBBI C STERNHEIM'
Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Sent: Thursday, April 8, 2021 5:06 PM
To: 'Laura Menninger' ; [REDACTED] (USANYS)
Cc: Jeff Pagliuca ; 'BOBBI C STERNHEIM'
Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
I plan to arrive at the warehouse on April 12 with an investigator and a paralegal at around 9:30am. Does that work?
Thanks,
Chris
Chris
From: Laura Menninger [mailto:lmenninger@hmflaw.com]
Sent: Wednesday, April 07, 2021 4:23 PM
To: [REDACTED] (USANYS)
Cc: Jeff Pagliuca; Christian Everdell; 'BOBBI C STERNHEIM'
Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Sent: Wednesday, April 07, 2021 4:23 PM
To: [REDACTED] (USANYS)
Cc: Jeff Pagliuca; Christian Everdell; 'BOBBI C STERNHEIM'
Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
My apologies, I meant to include in my previous email that we could have the Bronx view on Monday, April 12. Thank you for the logistics.
Regarding the spreadsheets you provided, I have several issues.
First, there are a couple of items that you have noted for the Bronx Warehouse but will in fact need to be brought to 500 Pearl for review because you labeled them as “Highly Confidential” and not “bulky.” These appear to include:
NY Evidence List
• Items 1B127-130 (4 boxes).
• Item 1B13 (1 box)
• Items 1B127-130 (4 boxes).
• Item 1B13 (1 box)
Florida Evidence List
• Item 1, Subitem 26 – one large framed photo from Master Bedroom.
• Item 1, Subitem 26 – one large framed photo from Master Bedroom.
Second, with regard to the “Bulky” photos (Florida Items 1, Subitems 8, 15a, 15b and 15c), are we permitted to photograph those or not? If not, we will need them transported to 500 Pearl.
Third, Florida Item 8, Subitem 8, says it is Sixteen DVD-R Discs from PBSO but you do not indicate that we can review those. Why? We need to address with the Court promptly any issues related to our request to view all evidence.
Fourth, Electronic surveillance – Your email yesterday stated that these were all “electronic files” with no corresponding physical item. However, for several, the chart indicates “Blu-Ray Disks;” is there a reason we cannot inspect these? Another Florida item is listed as “one original recording of an interview dated 4/24/07”; I am suspicious that “one original recording of an interview” is not truly only an “electronic” file? I was practicing law in 2007 and do not recall “electronic files” being the standard then. Can you please confirm? I know that Chris has written separately about the many files for which the metadata has apparently been stripped, so we will have to address purely electronic information at another date.
Shredded Paper – Yes, we need to review that as well.
“Missing from Assigned Box” items – can you please provide more of an explanation for all “missing items”?
I will let you know any other issues as I see them. However, now that we have made travel plans in reliance on your agreement to produce all evidence items, I am hoping that you can promptly answer these questions so that we can resolve any of them as needed this week.
Thank you,
-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
-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
From: [REDACTED]
Sent: Wednesday, April 7, 2021 1:44 PM
To: Laura Menninger ; [REDACTED] (USANYS)
Cc: Jeff Pagliuca ; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com); 'BOBBI C STERNHEIM'
Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Sent: Wednesday, April 7, 2021 1:44 PM
To: Laura Menninger ; [REDACTED] (USANYS)
Cc: Jeff Pagliuca ; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com); 'BOBBI C STERNHEIM'
Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Hi Laura,
The Bronx warehouse is located at 2350 Lafayette Ave, Bronx, NY. There is plenty of street parking outside of the building. Whatever day you wish to have the review conducted at the warehouse, an AUSA and an agent will meet the attorney, investigator, and paralegal at the warehouse to escort them into the building to the evidence review room. The AUSA will remain present at the warehouse to answer any questions that may arise.
The FBI has informed me that they can make the evidence available for review at the warehouse any day next week or the week of April 19th. Please just let me know what day you prefer, and we will coordinate with the FBI to arrange for the review.
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
[...Additional emails follow in the chain dating back to March 8, 2021 regarding logistics of evidence review at 500 Pearl Street vs Bronx Warehouse, specifically discussing massage tables, plaster busts, cash, and 2,100 highly confidential electronic images...]
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