EFTA00021898.pdf
162 KB
Extraction Summary
7
People
4
Organizations
2
Locations
2
Events
2
Relationships
3
Quotes
Document Information
Type:
Email chain
File Size:
162 KB
Summary
This document is an email chain from August 9-12, 2020, between defense attorneys (Jeff Pagliuca, Nicole Simmons, Christian Everdell, Mark Cohen) and the US Attorney's Office for the SDNY regarding a discovery dispute. The defense is pressing for a quick response to an August 9th letter, citing a tight schedule with the Circuit and threatening to advise Judge Nathan if they do not receive a response sooner than the Government's proposed date of August 13th. The correspondence also notes technical email issues at the defense firm Haddon, Morgan and Foreman.
People (7)
| Name | Role | Context |
|---|---|---|
| Jeff Pagliuca | Defense Attorney |
Partner at Haddon, Morgan and Foreman, P.C.; sending conferral letters regarding discovery to the government.
|
| Nicole Simmons | Defense Attorney |
Attorney at Haddon, Morgan and Foreman, P.C.; forwarding emails due to technical issues.
|
| Christian Everdell | Defense Attorney |
Attorney at Cohen & Gresser LLP; CC'd on correspondence.
|
| Mark S. Cohen | Defense Attorney |
Attorney at Cohen & Gresser LLP; CC'd on correspondence.
|
| Laura Menninger | Defense Attorney |
Attorney at Haddon, Morgan and Foreman, P.C.; CC'd on correspondence.
|
| Alex [Redacted] | Assistant U.S. Attorney |
Government prosecutor (SDNY); acknowledging receipt of letters.
|
| Judge Nathan | Judge |
Referenced by Pagliuca as the judge they may need to advise regarding the government's position (Judge Alison Nathan).
|
Organizations (4)
Timeline (2 events)
2020-08-10
2020-08-11
Dispute regarding timeline of Government response to discovery request.
Email correspondence
Jeff Pagliuca
SDNY Attorneys
Relationships (2)
Both at Haddon, Morgan and Foreman; Simmons forwards Pagliuca's email.
CC'd on same defense emails; different firms representing same interest (likely Ghislaine Maxwell).
Key Quotes (3)
"Absent any additional information from the government you are not leaving me with any realistic options and I will probably need to simply advise Judge Nathan that the government's position is forthcoming but because we learned about the information on Friday and the Circuit's tight schedule we could not wait any longer."Source
EFTA00021898.pdf
Quote #1
"We will provide you with our response by this Thursday, August 13th."Source
EFTA00021898.pdf
Quote #2
"Our firm is currently experiencing technical issues with our email system."Source
EFTA00021898.pdf
Quote #3
Full Extracted Text
Complete text extracted from the document (5,060 characters)
From: [Redacted] <[Redacted]>
To: Jeff Pagliuca
Cc: [Redacted] <[Redacted]>, Nicole Simmons , [Redacted] <[Redacted]>, "CEverdell@CohenGresser.com" , "mcohen@CohenGresser.com" , Laura Menninger
Subject: RE: Letter regarding discovery attached.
Date: Wed, 12 Aug 2020 20:51:58 +0000
Attachments: 2020-08-12_letter_to_GM_counsel_re_discovery.pdf
To: Jeff Pagliuca
Cc: [Redacted] <[Redacted]>, Nicole Simmons , [Redacted] <[Redacted]>, "CEverdell@CohenGresser.com" , "mcohen@CohenGresser.com" , Laura Menninger
Subject: RE: Letter regarding discovery attached.
Date: Wed, 12 Aug 2020 20:51:58 +0000
Attachments: 2020-08-12_letter_to_GM_counsel_re_discovery.pdf
Jeff,
Attached please find the Government's response to your August 9, 2020 letter.
Attached please find the Government's response to your August 9, 2020 letter.
Best,
[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: Jeff Pagliuca
Sent: Tuesday, August 11, 2020 11:45 PM
To: [Redacted] <[Redacted]>
Cc: [Redacted] <[Redacted]>; Nicole Simmons ; [Redacted] <[Redacted]>; CEverdell@CohenGresser.com; mcohen@CohenGresser.com; Laura Menninger
Subject: Re: Letter regarding discovery attached.
Sent: Tuesday, August 11, 2020 11:45 PM
To: [Redacted] <[Redacted]>
Cc: [Redacted] <[Redacted]>; Nicole Simmons ; [Redacted] <[Redacted]>; CEverdell@CohenGresser.com; mcohen@CohenGresser.com; Laura Menninger
Subject: Re: Letter regarding discovery attached.
[Redacted],
I'm not sure I can wait for a decision until Thursday. I will discuss with my colleagues and attempt to confer with the Government by phone tomorrow. Absent any additional information from the government you are not leaving me with any realistic options and I will probably need to simply advise Judge Nathan that the government's position is forthcoming but because we learned about the information on Friday and the Circuit's tight schedule we could not wait any longer.
I'm not sure I can wait for a decision until Thursday. I will discuss with my colleagues and attempt to confer with the Government by phone tomorrow. Absent any additional information from the government you are not leaving me with any realistic options and I will probably need to simply advise Judge Nathan that the government's position is forthcoming but because we learned about the information on Friday and the Circuit's tight schedule we could not wait any longer.
A phone call tomorrow would be appreciated.
Jeff
EFTA00021898
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On Aug 11, 2020, at 9:07 PM, [Redacted] <[Redacted]> wrote:
Jeff,
We are still considering your request, and we will reach out when we are prepared to provide you with our response, which will be no later than Thursday, August 13th.
We are still considering your request, and we will reach out when we are prepared to provide you with our response, which will be no later than Thursday, August 13th.
Best,
[Redacted]
[Redacted]
From: Jeff Pagliuca
Sent: Tuesday, August 11, 2020 7:28 PM
To: [Redacted] <[Redacted]>
Cc: [Redacted] <[Redacted]>; Nicole Simmons ; [Redacted] <[Redacted]>; CEverdell@CohenGresser.com; mcohen@CohenGresser.com; Laura Menninger
Subject: Re: Letter regarding discovery attached.
Sent: Tuesday, August 11, 2020 7:28 PM
To: [Redacted] <[Redacted]>
Cc: [Redacted] <[Redacted]>; Nicole Simmons ; [Redacted] <[Redacted]>; CEverdell@CohenGresser.com; mcohen@CohenGresser.com; Laura Menninger
Subject: Re: Letter regarding discovery attached.
Looks like our email is back up. As indicated in the gmail email I would like to discuss your position by phone tomorrow. I am available any time.
Jeff
On Aug 11, 2020, at 12:19 PM, [Redacted] <[Redacted]> wrote:
Good afternoon,
We will provide you with our response by this Thursday, August 13th. We will, of course, send the response sooner if we are able.
We will provide you with our response by this Thursday, August 13th. We will, of course, send the response sooner if we are able.
Best,
[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] <[Redacted]>
Sent: Monday, August 10, 2020 5:28 PM
To: Nicole Simmons ; [Redacted] <[Redacted]>; [Redacted] <[Redacted]>; CEverdell@CohenGresser.com; mcohen@CohenGresser.com
EFTA00021899
Sent: Monday, August 10, 2020 5:28 PM
To: Nicole Simmons ; [Redacted] <[Redacted]>; [Redacted] <[Redacted]>; CEverdell@CohenGresser.com; mcohen@CohenGresser.com
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Cc: Laura Menninger ; Jeff Pagliuca
Subject: RE: Letter regarding discovery attached.
Subject: RE: Letter regarding discovery attached.
Good afternoon,
We are in receipt of the email and letter. We will respond as soon as we are able.
We are in receipt of the email and letter. We will respond as soon as we are able.
Regards,
Alex.
[Redacted]
Assistant U.S. Attorney
Southern District of New York
212.637.2415
Alex.
[Redacted]
Assistant U.S. Attorney
Southern District of New York
212.637.2415
From: Nicole Simmons
Sent: Monday, August 10, 2020 16:18
To: [Redacted] <[Redacted]>; [Redacted] <[Redacted]>; CEverdell@CohenGresser.com; mcohen@CohenGresser.com
Cc: Laura Menninger ; Jeff Pagliuca
Subject: FW: Letter regarding discovery attached.
Sent: Monday, August 10, 2020 16:18
To: [Redacted] <[Redacted]>; [Redacted] <[Redacted]>; CEverdell@CohenGresser.com; mcohen@CohenGresser.com
Cc: Laura Menninger ; Jeff Pagliuca
Subject: FW: Letter regarding discovery attached.
Dear Counsel,
At the request of Jeffrey Pagliuca please see the attached letter. Our firm is currently experiencing technical issues with our email system. If you would please kindly confirm receipt of this email and the attachment it would be greatly appreciated.
At the request of Jeffrey Pagliuca please see the attached letter. Our firm is currently experiencing technical issues with our email system. If you would please kindly confirm receipt of this email and the attachment it would be greatly appreciated.
Thank you,
Nicole
Nicole
From: Jeff Pagliuca
Sent: Sunday, August 09, 2020 4:56 PM
To: [Redacted] <[Redacted]>; [Redacted] <[Redacted]>; [Redacted] <[Redacted]>
Cc: Laura Menninger ; Christian Everdell ; Mark S. Cohen ; Nicole Simmons
Subject: Letter regarding discovery attached.
Sent: Sunday, August 09, 2020 4:56 PM
To: [Redacted] <[Redacted]>; [Redacted] <[Redacted]>; [Redacted] <[Redacted]>
Cc: Laura Menninger ; Christian Everdell ; Mark S. Cohen ; Nicole Simmons
Subject: Letter regarding discovery attached.
Dear Counsel,
Please see attached conferral letter.
Please see attached conferral letter.
Jeff
Jeffrey S. Pagliuca
Haddon, Morgan and Foreman, P.C.
150 East 10th Avenue
Denver, Colorado 80203
Main 303.831.7364 FX 303.832.2628
jpagliuca@hmflaw.com
www.hmflaw.com
EFTA00021900
Haddon, Morgan and Foreman, P.C.
150 East 10th Avenue
Denver, Colorado 80203
Main 303.831.7364 FX 303.832.2628
jpagliuca@hmflaw.com
www.hmflaw.com
EFTA00021900
mation 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, printing, distribution or use of any of the information contained in or attached to this transmission is STRICTLY PROHIBITED. If you have received this transmission in error, please notify the sender by telephone or return e-mail and delete the original transmission and its attachments without reading or saving it in any manner. Thank you
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