HADDON, MORGAN & FOREMAN, P.C.
OrganizationRelationship Network
Event Timeline
| Connected Entity | Relationship Type |
Strength
(mentions)
|
Documents | Actions |
|---|---|---|---|---|
|
person
Laura A. Menninger
|
Employment affiliation |
5
|
1 | |
|
person
Ty Gee
|
Employment |
1
|
1 |
| Date | Event Type | Description | Location | Actions |
|---|---|---|---|---|
| 2013-07-17 | N/A | Decision rendered in Wolfe v. Foreman case. | Florida (Third District) | View |
037.pdf
This court document from April 7, 2017, details a 'Notice of Submission of Witness Solicitation Materials' filed in the case of Bradley J. Edwards v. Ghislaine Maxwell. Plaintiff Virginia Giuffre submitted witness solicitation materials for in camera review as per a March 23, 2017, court ruling. The document also includes a certificate of service, confirming electronic filing and service to attorneys Laura A. Menninger and Jeffrey S. Pagliuca.
EFTA00032783.pdf
This document is an email chain from April 22, 2021, concerning the case US v. Maxwell. It details internal communications within the US Attorney's Office (USANYS) regarding a draft response to a defense request for a 120 or 180-day trial adjournment. The chain includes an underlying email from Laura Menninger, counsel for Ghislaine Maxwell, submitting the motion to Judge Nathan and arguing for the redaction of other clients' names based on attorney-client privilege rules.
EFTA00032669.pdf
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.
EFTA00032465.pdf
This document contains a chain of legal correspondence between Ghislaine Maxwell's defense team (led by Laura Menninger) and the US Attorney's Office (SDNY) regarding the logistics of reviewing evidence for her trial. The discussions focus on protocols for accessing 'highly confidential' materials, specifically 2,100 nude or partially nude electronic images seized from Jeffrey Epstein's devices, which the government deems obscene and restricts from duplication. The emails also negotiate the transport of physical evidence, including computers, cash, and bulky items like massage tables and plaster busts, from an FBI warehouse in the Bronx to the courthouse at 500 Pearl Street.
EFTA00030084.pdf
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.
EFTA00030069.pdf
This document is an email chain from March 9, 2021, regarding the case U.S. v. Ghislaine Maxwell. Defense attorney Laura Menninger submits a letter to Judge Nathan detailing objections to the government's proposed redactions in an Omnibus Response. Subsequent emails in the chain involve coordination between the defense and the US Attorney's Office (USANYS) regarding the exchange of proposed redactions.
EFTA00030021.pdf
This document is a chain of emails between Ghislaine Maxwell's defense team (led by Laura Menninger) and the US Attorney's Office regarding the logistics of reviewing evidence for the case *US v. Maxwell*. The discussion focuses on the protocols for reviewing 'Highly Confidential' materials (specifically nude images and videos seized from Jeffrey Epstein's devices), the transport of physical evidence (including massage tables, plaster busts, and a stuffed dog) from the FBI Bronx warehouse to the courthouse, and the scheduling of Maxwell's transport by Marshals to 500 Pearl Street. The prosecution refuses to transport bulky items or obscene digital material freely, requiring the defense to view some items at the warehouse or on specific laptops under supervision.
EFTA00029843.pdf
This document is an email chain from March 9, 2021, regarding the legal case U.S. v. Ghislaine Maxwell (20 Cr. 330). Laura Menninger of Haddon, Morgan & Foreman, P.C. writes to Judge Nathan to submit a letter detailing Ms. Maxwell's objections to redactions proposed by the government in their Omnibus Response. The email includes several attachments related to these redactions and exhibits.
EFTA00029189.pdf
This document is an email thread from May 21, 2021, regarding the pretrial schedule for Ghislaine Maxwell (referenced as 'GM' in the attachment filename). Laura Menninger of Haddon, Morgan & Foreman, P.C. (defense counsel) contacts the recipients to coordinate a 'joint letter' and scheduling position statement. The recipient replies with a draft of the letter attached, noting it is '[sent_to_defense]'.
EFTA00028646.pdf
This document is a chain of emails between Ghislaine Maxwell's defense team (Cohen & Gresser; Haddon, Morgan & Foreman) and the US Attorney's Office (SDNY) regarding discovery production disputes in Spring 2021. Key issues include technical difficulties Maxwell faced in reviewing digital evidence at the MDC prison (specifically reading disks vs. hard drives), missing attachments for over 109,000 emails, and metadata discrepancies for 'carved' or deleted files recovered from Jeffrey Epstein's devices. The correspondence details the logistical back-and-forth regarding file formats, USAfx transfers, and the potential need for judicial intervention (Judge Nathan) to force the MDC to accept specific hard drives.
EFTA00028585.pdf
This document is an email chain between Ghislaine Maxwell's defense team (Cohen & Gresser; Haddon, Morgan & Foreman) and the US Attorney's Office (SDNY) regarding discovery disputes. The defense raises seven key issues, including over 109,000 emails missing attachments, metadata discrepancies on files extracted from Epstein's devices, and difficulties providing discovery materials to Maxwell at the MDC due to technical and bureaucratic limitations. The prosecution responds with technical explanations regarding FBI CART processes, 'carved' or deleted files lacking metadata, and the conversion of VHS/cassette tapes.
EFTA00028571.pdf
This document is a chain of email correspondence between Ghislaine Maxwell's defense team (Everdell, Menninger) and the US Attorney's Office (SDNY) regarding discovery disputes in Spring 2021. Key issues include the defense's inability to view certain files on prison computers, missing email attachments (over 109,000), and technical disputes over metadata for 'carved' or deleted files recovered from Jeffrey Epstein's electronic devices. The prosecution explains that metadata for deleted files was not recovered and that certain images (nude and non-nude) were seized from CDs in Epstein's residences rather than extracted by CART from devices.
EFTA00028183.pdf
This document is a chain of emails between the U.S. Attorney's Office (SDNY) and defense counsel for Ghislaine Maxwell (Laura Menninger) from March 2021. The correspondence concerns the scheduling of a review of 'highly confidential images' and physical evidence at 500 Pearl Street, as well as the production of indices listing items seized by the FBI from Jeffrey Epstein's residences in New York and the Virgin Islands in 2019. The prosecutor clarifies which items are indexed in spreadsheets versus search warrant returns and coordinates a phone call to discuss these matters.
EFTA00027167.pdf
This document is an email chain from April 22, 2021, involving the defense team for Ghislaine Maxwell and the US Attorney's Office (USANYS). Laura Menninger, representing Maxwell, emailed Judge Nathan attaching a Letter Motion for an adjournment of the trial (120 or 180 days) and requesting permission to redact names of other clients based on professional conduct rules. Subsequent emails between government attorneys discuss a draft response due by 5 PM that same day.
EFTA00027165.pdf
This document is an email chain from April 22, 2021, concerning the case US v. Maxwell. The initial email features Laura Menninger, defense counsel for Ghislaine Maxwell, submitting a Letter Motion for an adjournment of the trial to Judge Nathan and requesting redactions to protect client confidentiality under Rule 1.6. Subsequent emails show internal coordination among USANYS prosecutors drafting a response to this motion, which was due by 5 PM that day.
EFTA00026872.pdf
This document contains a series of email exchanges between Ghislaine Maxwell's defense team (led by Laura Menninger) and the US Attorney's Office regarding the logistics of reviewing discovery evidence in March and April 2021. The correspondence details disputes over the location of the review (FBI Bronx Warehouse vs. 500 Pearl Street courthouse), specifically concerning 'bulky' items such as massage tables, plaster busts, and framed art which the government refused to transport. Significant discussion focuses on the protocols for reviewing 'Highly Confidential' materials, including approximately 2,100 nude or obscene electronic images seized from Jeffrey Epstein's devices, which required specific viewing conditions on non-networked laptops due to their nature.
EFTA00025206.pdf
This document is an email chain from March 2021 between defense attorneys for Ghislaine Maxwell (Laura Menninger, et al.) and Assistant United States Attorneys for the Southern District of New York. The correspondence concerns scheduling a call to discuss evidence requests and includes the transmission of an index of physical items held in FBI custody by the Miami office. The prosecutor references a previous discovery production from August 2020 and specific Bates ranges for scanned items.
EFTA00025196.pdf
This document is a chain of emails from March 8-9, 2021, between defense attorney Laura Menninger and the US Attorney's Office (SDNY) regarding the case US v. Maxwell. The correspondence concerns a request to view evidence, specifically discussing spreadsheets indexing physical evidence seized by the FBI from Jeffrey Epstein's residences in New York and the US Virgin Islands in 2019. The prosecutors note that while some evidence is indexed in Excel, other items like search warrant returns are not, and they mention specific Bates ranges for previously produced scans.
EFTA00020322.pdf
This document is a chain of emails between Ghislaine Maxwell's defense counsel, Laura Menninger, and the US Attorney's Office (SDNY) regarding the logistics of reviewing physical and electronic evidence. The discussion focuses on arranging a secure location (500 Pearl Street) for Maxwell and her team to review 'highly confidential' materials, including thousands of images seized from Jeffrey Epstein's devices and residences, as well as physical evidence stored in an FBI warehouse. The defense raises concerns about access to laptops, the ability to compare physical and electronic evidence, and the specific handling of sensitive materials.
EFTA00016508.pdf
This document is an email chain from November 2021 regarding legal proceedings. Laura Menninger of Haddon, Morgan & Foreman, P.C. sends a supplemental letter to USANYS counsel regarding the anticipated testimony of a redacted individual (Mr. [Redacted]). The forwarding email references 'Flatley and their rebuttal expert,' suggesting the correspondence concerns expert witness testimony or rebuttal.
EFTA00015804.pdf
This document is an email chain between Ghislaine Maxwell's defense team and the US Attorney's Office (SDNY) regarding the logistics of reviewing discovery evidence in March and April 2021. The discussions concern protocols for viewing 'highly confidential' materials, including nude images and physical evidence (such as massage tables and plaster busts) seized from Jeffrey Epstein's properties. The parties negotiate the location of the review (FBI Bronx warehouse vs. 500 Pearl Street courthouse), the presence of the defendant, and the use of electronic devices by defense counsel during the review.
EFTA00015770.pdf
This document is a chain of emails between Ghislaine Maxwell's defense team (led by Laura Menninger) and the US Attorney's Office (SDNY) regarding the logistics of reviewing evidence for the case *US v. Maxwell*. The correspondence details negotiations over the location of the review (500 Pearl St vs. FBI Bronx Warehouse), the transportation of specific physical evidence (including excluding 'bulky' massage tables and cash), and protocols for viewing 'highly confidential' and 'obscene' electronic images seized from Jeffrey Epstein's properties. The defense expresses concerns about missing items, the format of electronic surveillance, and the need for their client to meaningfully participate in the review.
EFTA00015753.pdf
This document contains a chain of email correspondence between Ghislaine Maxwell's defense team (Menninger, Everdell) and the US Attorney's Office (SDNY) regarding the logistics of reviewing evidence for case 20 Cr. 330. The discussions focus on scheduling physical evidence reviews at an FBI warehouse in the Bronx and electronic evidence reviews at the 500 Pearl Street courthouse. Key evidence items discussed include massage tables, plaster busts, cash, shredded paper, and thousands of 'highly confidential' nude or partially nude images seized from Jeffrey Epstein's devices and residences.
EFTA00015738.pdf
This document is a chain of email correspondence between Ghislaine Maxwell's defense team (led by Laura Menninger) and the US Attorney's Office (SDNY) regarding the logistics of reviewing evidence for the case US v. Maxwell. The emails discuss the scheduling of Maxwell's transport by Marshals to 500 Pearl Street to review 'Highly Confidential' materials, including 2,100 nude/partially nude images seized from Jeffrey Epstein's electronic devices. The correspondence also details disputes over the transport of physical evidence from an FBI warehouse in the Bronx, specifically mentioning 'bulky' items like massage tables, plaster busts of female torsos, and a stuffed dog, which the government argued were difficult to transport.
EFTA00014669.pdf
This document is an email thread from May 2021 regarding the case US v. Maxwell. An Assistant United States Attorney contacts Ghislaine Maxwell's defense team (Laura Menninger, et al.) to dispute a claim made in a recent filing that the defense had made multiple unanswered attempts to confer with the government regarding specific photographs. The AUSA requests the defense either identify these communications or correct the representation to the Court. The thread includes the underlying email from Laura Menninger to Judge Nathan's chambers submitting the filing in question.
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