This document is an email chain from November 5-10, 2020, involving the FBI New York Field Office's Child Exploitation/Human Trafficking unit. The correspondence coordinates a visit to the Metropolitan Detention Center (MDC) to review a laptop, referencing Case Number 50D-NY-3027571. It notes that an FBI Special Agent retained the computer after the November 6th visit and discusses scheduling a follow-up viewing.
This document is an email chain dated August 9, 2019, the day before Jeffrey Epstein's death. The subject line discusses 'Prisoner Production' scheduled for August 12, 2019. The text includes operational notes such as 'MDC ONLY', 'ADD ON 3 CADRE MALES', and 'WAB/MED SUMMARY', likely referring to prison logistics and medical summaries.
This document is a chain of emails between Ghislaine Maxwell's defense attorney, Bobbi Sternheim, and government officials (likely BOP/MDC) regarding her conditions of confinement in June 2021. Sternheim alleges that guards are sleep-depriving Maxwell by waking her at 1 AM and 3 AM when she shivers from cold, and subsequently confiscated her blankets. The correspondence also debates the quality of VTC (video) connections for legal preparation and the behavior of guards, which the defense characterizes as hostile and the prosecution characterizes as enforcing orders.
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.
An email chain from June 10, 2021, regarding legal discovery materials for Ghislaine Maxwell at the Metropolitan Detention Center (MDC). MDC staff member Sophia informed USANYS (Maurene) that a disc provided to Maxwell was scratched and unreadable. USANYS contractors subsequently burned a replacement disc to be sent to the facility.
This document is an email dated April 14, 2021, from an Assistant United States Attorney in the Southern District of New York to defense counsel regarding the case US v. Maxwell. The email serves as a transmittal for discovery materials, specifically an additional photograph and a cover letter, which are being prepared on a drive for the client (Ghislaine Maxwell) to review at the Metropolitan Detention Center (MDC).
This document is an email thread from August 2020 between staff and contractors at the US Attorney's Office for the Southern District of New York (SDNY). The discussion concerns the logistics of providing discovery materials (letters and digital files) to the Metropolitan Detention Center (MDC) regarding Ghislaine Maxwell. Technical issues with McAfee software preventing the burning of DVDs are noted, leading to alternative arrangements for transferring files to defense counsel.
This document is an email chain between the US Attorney's Office (SDNY) and Ghislaine Maxwell's defense counsel (Cohen & Gresser LLP) regarding discovery disputes in early 2021. The correspondence details logistical issues with providing Maxwell access to 4TB hard drives at the MDC, disputes over unredacted FBI reports from 2006 found on Jeffrey Epstein's devices, and missing metadata/Bates ranges. The defense specifically notes missing 'flight logs' from a redacted provider and questions the unsealing of a search warrant affidavit referenced in a Daily Beast article. No actual flight data is contained in the document, only a reference to missing logs.
This document is an email chain from January 2021 between the US Attorney's Office (SDNY) and likely MDC staff or defense counsel. It coordinates the logistical delivery of 'two new drives' for Ghislaine Maxwell at the Metropolitan Detention Center (MDC). An FBI Special Agent was utilized to transport the materials from the SDNY office (referred to as 1SA/1 St. Andrew's Plaza) to the detention facility.
An email dated October 20, 2020, from an Assistant United States Attorney (SDNY) to a redacted recipient (likely at the MDC). The email coordinates the delivery of a hard drive containing new discovery materials for Ghislaine Maxwell via FedEx and requests confirmation upon delivery to the defendant.
This document is an email chain from October to November 2020 between US Attorney's Office (SDNY) staff and other legal personnel regarding the provision of a 'clean' laptop to Ghislaine Maxwell at the Metropolitan Detention Center (MDC). The laptop was requested to allow Maxwell to review discovery materials (PDFs, Word docs, etc.) due to accessibility issues, citing the Michael Avenatti case as a precedent. The emails confirm that the MDC Warden approved the request and discuss the logistics of purchasing and preparing the device within Bureau of Prisons (BOP) regulations.
This document is an email thread among US Attorney's Office (SDNY) staff regarding a court order from Judge Engelmayer in the case of United States v. Justin Rivera. The Judge required the BOP to explain why Ghislaine Maxwell (detained at MDC) received significantly better access to legal counsel and laptops than Rivera (detained at MCC), specifically citing 'terrible optics' and potential disparity based on class/race. The emails detail the drafting of a declaration to explain that the differences are due to Maxwell's protective custody status and the sheer volume of discovery in her case, compared to Rivera's placement in the general population.
This document is a chain of emails from September 2020 between the US Attorney's Office (SDNY) and contractors regarding the discovery process in the US v. Epstein/Maxwell case. The correspondence details the technical logistics of uploading roughly 40,000 files (300GB), labeled as 'Images Seized During Search', to the Relativity database. Key topics include handling native file formats (Excel/Text), verifying if Ghislaine Maxwell can open these files on BOP computers at the MDC, and managing confidential stamping for the production. References are also made to productions involving Deutsche Bank and JPMorgan.
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.
This document is an email thread between an Assistant U.S. Attorney for the Southern District of New York and staff at the Metropolitan Detention Center (MDC) regarding the protocol for delivering a hard drive containing discovery materials to inmate Ghislaine Maxwell. The conversation, spanning August 5-13, 2020, covers the requirements for mailing the drive (etching, authorization memo, password protection) and confirms the delivery of the package via FedEx.
This document is an email chain from August 2020 between an Assistant U.S. Attorney (SDNY) and staff at the Metropolitan Detention Center (MDC). The correspondence coordinates the delivery of discovery materials (hard drives) to inmate Ghislaine Maxwell. The emails discuss protocols for mailing hard drives, including etching requirements, authorization memos, and password protection policies.
This document is a discovery request letter from attorney Jason E. Foy, representing Tova Noel (a guard charged in relation to Jeffrey Epstein's death), to the US Attorney's Office. The letter demands 31 specific items, including Noel's personnel files, SHU logs from the time of Epstein's death (August 2019), surveillance records of broken cameras, and internal memos regarding Epstein's need for a cellmate. It also notably asks for the identity of the author of a specific 4Chan message and records related to other inmate deaths at the MDC.
This document is an email chain from January 2021 between the US Attorney's Office (SDNY) and MDC staff regarding the delivery of legal discovery materials (hard drives) to Ghislaine Maxwell. The FBI assisted in transporting the drives. The delivery was delayed because the paralegal responsible for logging the drives was absent, and when delivery was attempted, Maxwell was occupied with a Video Teleconference (VTC).
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.
This document is an email dated October 29, 2020, from an Assistant United States Attorney at the Southern District of New York to a redacted recipient. The email notifies the recipient that a CD containing replacement discovery files for Ghislaine Maxwell has been sent to the Metropolitan Detention Center (MDC) via FedEx overnight delivery.
This document is an email chain from October 28-29, 2020, between staff at the U.S. Attorney's Office (USANYS). They discuss procuring a 'clean' laptop for Ghislaine Maxwell while she is detained at the Metropolitan Detention Center (MDC) to facilitate her review of discovery materials for her case. The emails detail specific security requirements mandated by the Bureau of Prisons (BOP) Legal department, such as disabling WiFi, Bluetooth, and recording capabilities, and reference a similar arrangement made in the Michael Avenatti case.
This document is a heavily redacted email dated November 2, 2021. The subject line refers to 'mail sent last week' and includes an attachment titled '2021-11-01_GM_letter_re_MDC_legal_mail_v3.docx', suggesting correspondence regarding Ghislaine Maxwell's legal mail at the Metropolitan Detention Center. The body of the email simply asks the recipient to look at a version of a document, likely the attachment.
This document is an email chain between the US Attorney's Office (SDNY) and Bureau of Prisons/MDC officials regarding Ghislaine Maxwell shortly after her arrest in July 2020. Key topics include scheduling urgent legal calls for her defense counsel (Mr. Everdell) ahead of deadlines and her arraignment, establishing a standing 10:00 AM call schedule, and confirming her housing conditions (solitary cell and separate exercise) for court filings. BOP officials note that Maxwell was receiving significantly more legal access (2-hour afternoon calls plus morning calls) than typical inmates.
This document is an email chain from July 6-11, 2020, between the US Attorney's Office (SDNY) and prison officials (MDC) regarding Ghislaine Maxwell shortly after her arrest. The emails coordinate urgent legal calls between Maxwell and her defense counsel (specifically Mr. Everdell) ahead of court deadlines and her arraignment scheduled for July 14, 2020. There is discussion regarding a 'standing legal call' at 10:00 AM and adherence to EDNY/SDNY protocols for scheduling inmate calls.
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