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EFTA00014710.pdf

142 KB

Extraction Summary

7
People
4
Organizations
2
Locations
1
Events
2
Relationships
3
Quotes

Document Information

Type: Email correspondence
File Size: 142 KB
Summary

This document is an email chain from November 2021 regarding *U.S. v. Maxwell*. Defense attorneys Bobbi Sternheim and Nicole Simmons communicate with Judge Nathan's chambers about submitting Ghislaine Maxwell's response to motions to quash a subpoena issued to the Epstein Victims' Compensation Program (EVCP). The correspondence confirms that the response was submitted under temporary seal and that the government and moving parties were subsequently served after redactions were handled.

People (7)

Name Role Context
Bobbi C. Sternheim Defense Attorney
Sent multiple emails to the Court confirming service of documents and coordination with the government.
Alison J. Nathan Judge
Presiding Judge over U.S. v. Maxwell; her chambers is the recipient of the emails.
Nicole Simmons Defense Attorney
Sent initial email submitting Maxwell's Response to Letter Motions to Quash.
Jeff Pagliuca Defense Attorney
Cc'd on emails; requested Nicole Simmons to send the attachment.
Laura Menninger Defense Attorney
Cc'd on emails.
Christian Everdell Government Counsel (AUSA)
Cc'd on emails; implied as 'the government' conferred with regarding redactions.
Ghislaine Maxwell Defendant
Subject of the case (U.S. v. Maxwell); document discusses her response to motions.

Organizations (4)

Name Type Context
Law Offices of Bobbi C. Sternheim
Firm representing the defendant.
Nathan NYSD Chambers
Chambers of the Judge in the Southern District of New York.
Haddon, Morgan and Foreman, P.C.
Law firm representing the defendant (Nicole Simmons, Jeff Pagliuca).
Epstein Victims' Compensation Program
Referred to as EVCP; subject of a subpoena and motions to quash.

Timeline (1 events)

2021-11-22
Submission of Maxwell's Response to Letter Motions to Quash Rule 17(c) subpoena to the Epstein Victims' Compensation Program.
US District Court SDNY (via email)

Locations (2)

Location Context
Address for Law Offices of Bobbi C. Sternheim.
Address for Haddon, Morgan and Foreman, P.C.

Relationships (2)

Bobbi C. Sternheim Attorney-Client Ghislaine Maxwell
Sternheim acts as counsel for Maxwell in this correspondence.
Nicole Simmons Colleagues Jeff Pagliuca
Both work at Haddon, Morgan and Foreman, P.C.; Simmons writes 'At the request of Jeffrey Pagliuca'.

Key Quotes (3)

"The government has confirmed that all moving parties have been served."
Source
EFTA00014710.pdf
Quote #1
"They have informed us that the EVCP has been served."
Source
EFTA00014710.pdf
Quote #2
"Ms. Maxwell's Response to the Letter Motions to Quash her Rule 17(c) subpoena to the Epstein Victims' Compensation Program."
Source
EFTA00014710.pdf
Quote #3

Full Extracted Text

Complete text extracted from the document (4,157 characters)

From: BOBBI C STERNHEIM
To: Nathan NYSD Chambers
Cc: Nicole Simmons , Jeff Pagliuca , Laura Menninger , "Christian Everdell"
Subject: [EXTERNAL] Re: U.S. v. Maxwell, Case No. 20 Cr. 330 (AJN) [Maxwell's Resp to Ltr. Motns to Quash EVCP Sub ]
Date: Tue, 23 Nov 2021 00:36:45 +0000
Good evening-
The government has confirmed that all moving parties have been served.
Best-
Bobbi
Please note my new office address and preferred email address:
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
225 Broadway, Suite 715
New York, NY 10007
Main: REDACTED
Cell: REDACTED
Fax: REDACTED
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.
On Nov 22, 2021, at 6:27 PM, BOBBI C STERNHEIM wrote:
Good evening-
We have conferred with the government and they have agreed to serve the moving parties after applying appropriate redactions.
They have informed us that the EVCP has been served. We will inform the Court when the government has served the remaining parties.
Best-
Bobbi
Please note my new office address and preferred email address:
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
225 Broadway, Suite 715
New York, NY 10007
Main: REDACTED
Cell: REDACTED
Fax: REDACTED
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.
On Nov 22, 2021, at 5:37 PM, BOBBI C STERNHEIM wrote:
Good afternoon:
We have contacted the government and are awaiting a response to work through any redaction issues.
We will notify the Court as soon as service has been completed.
Best-
Bobbi
Please note my new office address and preferred email address:
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
225 Broadway, Suite 715
New York, NY 10007
Main: REDACTED
Cell: REDACTED
Fax: REDACTED
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.
On Nov 22, 2021, at 5:07 PM, Nathan NYSD Chambers wrote:
Counsel:
Please confirm as soon as possible that a copy of the response was served on counsel for the moving parties.
Sincerely,
Chambers of the Hon. Alison J. Nathan
From: Nicole Simmons
Sent: Monday, November 22, 2021 1:40 PM
To: Nathan NYSD Chambers
Cc: Jeff Pagliuca ; Laura Menninger ; bcsternheim_mac.com ; REDACTED; REDACTED
Subject: U.S. v. Maxwell, Case No. 20 Cr. 330 (AJN) [Maxwell's Resp to Ltr. Motns to Quash EVCP Sub ]
CAUTION - EXTERNAL:
Dear Judge Nathan:
At the request of Jeffrey Pagliuca, please see attached Ms. Maxwell's Response to the Letter Motions to Quash her Rule 17(c) subpoena to the Epstein Victims' Compensation Program.
Pursuant to our established protocol, we are submitting the Response to the Court under temporary seal to allow the government to propose any redactions it deems necessary.
Regards,
Nicole
Nicole Simmons
Haddon, Morgan and
Foreman, P.C.
150 East 10th Avenue
Denver, Colorado
80203
PH REDACTED FX
DIRECT: REDACTED
www.hmflaw.com
CAUTION - EXTERNAL EMAIL: This email originated outside the Judiciary. Exercise caution when opening attachments or clicking on links.
EFTA00014710
EFTA00014711
EFTA00014712

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