This document is an email dated April 10, 2020, from attorney Montell Figgins to opposing counsel (recipients redacted). It serves as a transmittal for a refiled 'Motion to Compel Discovery' in the case of USA v. Michael Thomas, et al. Michael Thomas was one of the guards charged in connection with Jeffrey Epstein's death in custody.
This document contains an email chain between USANYS employees regarding a 'Sharing Order Part II' related to the Epstein case. The correspondence, dating from January 2020 to June 2020, discusses the procedural details of sharing additional trust and will documents (specifically 'Trust Two' and '2019 Trust') with the Civil Division. Key details include a reference to a prior miscellaneous court number (19 Misc. 0586) and a Rule 6(e) order.
This document is an email dated September 2, 2021, from an Assistant United States Attorney (SDNY) regarding the case US v. Maxwell. The email attaches the Government's proposed redactions to Ghislaine Maxwell's 'Second Ex Parte and In Camera Motion' for a subpoena pursuant to Fed. R. Crim. P. 17(c)(3). The sender's name and recipient list are redacted.
This email chain from August 2019 between an SDNY Assistant U.S. Attorney and an MCC Staff Attorney discusses conditions for an inmate formerly housed with Jeffrey Epstein. The emails detail checks made by the Facilities Manager regarding a complaint about shower leaks, confirm the inmate received newspapers, and recount a past interaction where a correction officer offered to take both Epstein and the inmate to roof recreation at 6:00 AM. Attorney Bruce Barket is mentioned as having filed a letter on ECF related to the matter.
This document is an email dated April 8, 2021, from attorney Bobbi C. Sternheim regarding the case U.S. v. Maxwell. Sternheim is sending a courtesy copy of an ECF filing, specifically a reply letter concerning the MDC (Metropolitan Detention Center), to redacted recipients and co-counsel including Christian Everdell, Laura Menninger, and Jeff Pagliuca.
This document is an email chain from November and December 2019 between the administrators of the Epstein Victims' Compensation Program (Jordy Feldman) and legal counsel for the victims (Roberta Kaplan's firm). The correspondence centers on the victims' counsel challenging the independence of the program, arguing that because the administrators were hired and paid by the Epstein Estate, they cannot be neutral. Kaplan's team proposes adding a fourth administrator selected by the plaintiffs to ensure fairness.
An email dated October 15, 2021, from attorney Bobbi C. Sternheim regarding the case U.S. v. Maxwell (S2 20 Cr. 330). The email serves to distribute a courtesy copy of a defense filing (Defense_Reply_to_Dkt_350.pdf) to redacted recipients, copying attorneys Christian Everdell, Laura Menninger, and Jeff Pagliuca.
This document is an email dated October 19, 2021, from an Assistant US Attorney in the Southern District of New York to the legal defense team of Ghislaine Maxwell (including Christian Everdell, Bobbi Sternheim, Laura Menninger, and Jeff Pagliuca). The email serves to serve the Government's 'motions in limine' and requests that certain attached documents be filed under seal. The email references case number 20 Cr. 330 (AJN).
This document is an internal email from an Assistant US Attorney at the Southern District of New York (SDNY) dated February 17, 2021. The sender discusses a defense motion regarding the Non-Prosecution Agreement (NPA), noting that the defense is using a Southern District of Florida (SDFL) privilege log to argue that investigations were coordinated. The sender is attempting to identify a specific attorney (whose name is redacted) mentioned in that log who allegedly had handwritten notes, but cannot find any record of this person in NY registration or SDNY files.
This document is an email dated July 2, 2020, from an Assistant US Attorney in the SDNY to Judge Nathan regarding the case 'United States v. Maxwell'. The email submits a memorandum in support of detention for Ghislaine Maxwell and notes that a copy is being provided to the Magistrate Judge in New Hampshire for proceedings occurring that afternoon. Defense counsel Jeff Pagliuca is copied on the correspondence.
This document is an email from attorney Bobbi C. Sternheim dated November 24, 2020, regarding the case 'U.S. v. Maxwell'. The email circulates a courtesy copy of an ECF filing titled 'Maxwell_Reply_to_90-day_conditions_ltr.pdf' to a group of attorneys including Mark S. Cohen, Christian Everdell, Laura Menninger, and Jeff Pagliuca.
This document is an email dated November 13, 2021, from an Assistant United States Attorney to Judge Nathan's chambers regarding the case United States v. Ghislaine Maxwell. The email submits a letter and exhibit 'GX-52' (referenced in attachments) and requests that the exhibit be filed under seal. Defense attorneys Christian Everdell, Laura Menninger, and Jeff Pagliuca are copied on the correspondence.
An email dated April 26, 2021, from defense attorney Bobbi C. Sternheim to the US Attorney's Office (USANYS) and other counsel. The email serves to provide a courtesy copy of a letter filed that day via ECF in the case U.S. v. Maxwell (Ghislaine Maxwell). Co-counsel Christian Everdell, Laura Menninger, and Jeff Pagliuca are cc'd.
This document is an email from attorney Bobbi C. Sternheim dated January 15, 2021, communicating a court order to an unidentified recipient (likely prison officials). The email contains the text of a Memo Endorsement signed by Judge Alison J. Nathan, which orders the Bureau of Prisons to grant Ghislaine Maxwell access to her laptop on weekends and holidays for reviewing discovery materials.
This document is an email chain from November and December 2019 between Jordy Feldman (Administrator of the Epstein Victims' Compensation Program) and attorneys Roberta Kaplan and Kate Doniger (representing victims). The core conflict involves the independence of the Compensation Program; Kaplan's team argues that because the administrators were hired by the Estate, they lack independence, and proposes adding a fourth, plaintiff-selected administrator. Feldman rejects this proposal, citing the reputation and experience of his team (including Ken Feinberg and Camille Biros) and asserting the program's neutrality.
This document is an email chain dated October 19, 2020, circulating a 'Notice of Docket Activity' from the U.S. Court of Appeals for the 2nd Circuit. The notice confirms that Ghislaine Maxwell's appeal (Case 20-3061) regarding a protective order modification was dismissed on jurisdictional grounds. The email correspondents, whose names are redacted, celebrate the dismissal as 'Good news' and commend the team's performance at oral argument.
An email thread from July 2020 between the US Attorney's Office (SDNY) and unknown recipients regarding the case US v. Maxwell. An Assistant US Attorney provides the grand jury return for a superseding indictment, noting it is unsealed and was presented to Judge Nathan. A subsequent email requests the immediate docketing of the indictment on ECF to ensure notice is given before the defendant's upcoming arraignment.
This document is an email dated December 7, 2020, with the subject 'Ghislaine Maxwell (02879-509)'. The sender and recipients are redacted. The body text states that a courtesy copy of an ECF filing responding to a letter from the MDC (Metropolitan Detention Center) is attached. The attachment is listed as 'GM_RESPONSE_TO_MDC_LEGAL.pdf'.
An email dated April 20, 2021, from an Assistant US Attorney in the Southern District of New York to Ghislaine Maxwell's defense team (Everdell, Cohen, Sternheim, Menninger, Pagliuca). The email serves filing notice for a letter regarding redactions to the defense's reply briefs in the case US v. Maxwell, 20 Cr. 330 (AJN).
This is a page from a court transcript filed on August 10, 2022, related to case 1:20-cr-00330-PAE (Ghislaine Maxwell). The text details a legal argument regarding the redaction of documents to protect the identity of a person referred to as 'Jane' from being cross-referenced with public records on PACER. The Judge instructs the attorneys (Ms. Moe and Mr. Rohrbach) to find a middle ground that protects witness privacy while acknowledging facts already in the public trial transcript before the jury enters.
This is page 4 of a legal filing from September 24, 2020, in Case 20-3061. Ms. Maxwell's legal counsel requests permission to file several documents under seal, including an unredacted opening brief, Appendix Volume 2 (which is entirely confidential), and a response to the government's opposition. The document notes that the government does not oppose this motion.
This legal document, dated September 24, 2020, is a filing in which Ms. Maxwell requests permission from the court to be excused from publicly filing a redacted version of 'Appendix Volume 2'. The justification is that the appendix and related briefs contain confidential information shielded by a criminal protective order. The filing connects this request to two ongoing appeals she has filed: one against an order by Judge Nathan and another against an order by Judge Preska in the related case of Giuffre v. Maxwell, with a consolidated oral argument scheduled for October 13.
This legal document, part of an appeal (Case 20-3061), explains the procedural constraints on Ms. Maxwell due to conflicting court orders. A criminal protective order from Judge Nathan prevents her from sharing critical information with Judge Preska in a related civil case. Consequently, Ms. Maxwell must file a redacted version of her Motion to Consolidate publicly, while the full, unredacted version can only be filed under seal in the criminal appeal.
This document is a page from a legal filing dated October 8, 2020, in Case 20-3061. It details a request by Ghislaine Maxwell's legal team to file an unredacted reply brief under seal because it references material shielded by a criminal protective order and deposition material unsealed by Judge Preska. The filing notes that the government has been consulted and does not oppose this motion.
This document is a Certificate of Service filed on October 29, 2021, certifying that on October 18, 2021, Nicole Simmons electronically filed Ghislaine Maxwell's 'Motion to Exclude' and 'Request for Daubert Hearing.' The notification of this filing was sent to prosecutors Alison Moe, Maurene Comey, Andrew Rohrbach, and Lara Pomerantz at the U.S. Attorney's Office in the Southern District of New York.
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