MDC
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EFTA00023753.pdf
This document is an email dated June 11, 2020, from an Assistant US Attorney (AUSA) in the Eastern District of New York (EDNY). The prosecutor is investigating an inmate death at Brooklyn MDC and requests a copy of the confidentiality agreement the Office of Chief Medical Examiner (OCME) signed regarding the 'investigation into the murder of Jeffrey Epstein.' The use of the word 'murder' instead of 'suicide' in an official correspondence regarding Epstein's death is a notable anomaly.
EFTA00023705.pdf
Email correspondence from September 30, 2020, between defense attorney Christian Everdell and the US Attorney's Office (SDNY). Everdell requests access to roughly 40,000 non-nude images seized from Jeffrey Epstein's residences in New York and the Virgin Islands for his client, Ghislaine Maxwell, to review at the MDC. The AUSA responds that they are coordinating with the FBI to transport a laptop with the files to the detention center, though the large volume of files requires a few days for processing.
EFTA00023481.pdf
An email chain from October 2021 between Ghislaine Maxwell's attorney, Bobbi Sternheim, and likely prison or government officials. Sternheim complains about conditions during a legal visit (broken HEPA filters), requests use of a larger visiting room, and reports that legal mail sent to the MDC has not been picked up. The recipient acknowledges the concerns and promises to inquire with staff.
EFTA00023478.pdf
This document is an email dated October 4, 2021, from an Assistant United States Attorney (SDNY) to the defense team for Ghislaine Maxwell (Everdell, Cohen, Sternheim, Menninger, Pagliuca). The email serves as a transmittal notice for an additional discovery production in the case US v. Maxwell (20 Cr. 330). The prosecutor notes that digital files are being sent via USAfx and a physical CD is being sent to the Metropolitan Detention Center (MDC) for Ms. Maxwell.
EFTA00023458.pdf
This document is an email thread dated October 29, 2021, regarding urgent legal mail issues for inmate Ghislaine Maxwell. Attorney Bobbi C. Sternheim complains that the MDC has failed to retrieve four items of legal mail despite them being available for pickup, noting Maxwell hasn't received legal mail in over a week. The response from a redacted official briefly states that mail was picked up that day. The footer reveals involvement from Isabel Maxwell acting as a paralegal for the Law Offices of Leah Saffian.
EFTA00023213.pdf
Legal correspondence from attorney Bobbi Sternheim regarding the conditions of confinement for Ghislaine Maxwell at the MDC. Sternheim complains that HEPA filters were not functioning during a visit on October 25, 2021, necessitating a move to a larger room, and requests that future visits occur in that larger room. Additionally, she provides tracking numbers for legal mail that has been sitting at the post office in Brooklyn without being picked up by the facility.
EFTA00023118.pdf
This document is an email thread from October 2021 involving defense attorney Bobbi C. Sternheim regarding the confinement conditions of Ghislaine Maxwell (Inmate 02879-509) at the MDC. Sternheim complains that during a visit on Oct 24, HEPA filters were broken in the small visiting room and requests future visits be moved to a larger corner room, noting that officers successfully positioned cameras there despite previous denials. Additionally, Sternheim raises urgent concerns about legal mail sent to the MDC not being picked up by the facility.
EFTA00023037.pdf
An email chain from October 12, 2021, in which attorney Bobbi C. Sternheim informs recipients (likely MDC officials) that the government has sent a hard drive to the Metropolitan Detention Center (MDC) for Ghislaine Maxwell via Federal Express. Sternheim emphasizes that the hard drive must be given to Maxwell immediately upon arrival as time is of the essence.
EFTA00023026.pdf
This document is an email chain between Ghislaine Maxwell's defense counsel (Christian Everdell) and the US Attorney's Office (SDNY) regarding discovery disputes in January 2021. The defense raises issues about defective hard drives provided to Maxwell in prison, missing pages from pilot David Rodgers' flight logs (specifically pages 1-27), and requests unredacted FBI reports from 2006. The government responds that the 'missing' flight log pages are accounted for in a separate document, asserts that redactions in the FBI report were original to the files found on Epstein's devices, and denies requests for grand jury subpoenas.
EFTA00022514.pdf
This document is a letter motion filed by Ghislaine Maxwell's defense attorney, Christian Everdell, on April 30, 2021, requesting Judge Alison Nathan to order the Metropolitan Detention Center (MDC) to accept two hard drives containing discovery materials for Maxwell's review. The defense argues the current format of 2.2 million pages is difficult to navigate, and they have reorganized the files to be more user-friendly. Judge Nathan granted the order on May 3, 2021, with a stipulation allowing MDC counsel to submit objections by May 4, 2021.
EFTA00022051.pdf
An email dated October 19, 2020, from a Paralegal Specialist at the U.S. Attorney's Office (SDNY) regarding the '5th Production' of discovery materials. The email outlines the procedure for sending hard drives and password-protected cover letters to Ghislaine Maxwell at the MDC (Metropolitan Detention Center) and defense counsel.
EFTA00022023.pdf
This document is an email dated June 15, 2021, from attorney Bobbi C. Sternheim to redacted recipients and copied to Christian Everdell, Laura Menninger, and Jeff Pagliuca. The subject concerns 'US v. Maxwell' and an update on conditions at the MDC (Metropolitan Detention Center). The email attaches a letter with requested redactions highlighted regarding these conditions.
EFTA00021965.pdf
This is an email dated November 6, 2021, from an Assistant United States Attorney (SDNY) to Ghislaine Maxwell's defense team (Everdell, Sternheim, Menninger, Pagliuca). The email serves as a cover for a supplemental production of discovery material, specifically regarding testifying and non-testifying witnesses, to be delivered via USAfx and a hard drive sent to the MDC.
EFTA00021877.pdf
An email chain between an Assistant U.S. Attorney from the Southern District of New York and staff at the Metropolitan Detention Center (MDC) regarding the protocol for delivering a hard drive containing legal discovery materials to inmate Ghislaine Maxwell. The correspondence clarifies that the drive must be etched with an ID number, accompanied by an authorization memo, and mailed to the legal department. The AUSA confirms they will mail the drive, and a follow-up email from MDC staff on August 10 asks for carrier details to locate the package.
EFTA00021873.pdf
This document is an email chain from August 5, 2020, between an Assistant U.S. Attorney from the Southern District of New York and an official at the MDC (Metropolitan Detention Center). The discussion concerns the protocol for delivering a hard drive containing discovery materials to inmate Ghislaine Maxwell. The facility official instructs that the drive can be password protected if the password is provided in a cover letter, and that the drive must be etched with a number and accompanied by an authorization memo.
EFTA00021732.pdf
This document contains a chain of emails from January 15, 2021, involving defense attorney Bobbi Sternheim regarding the refusal of MDC staff to comply with a court order granting Ghislaine Maxwell access to a laptop for discovery review. Despite Judge Nathan's order issued that same day, an Officer Regan allegedly told Maxwell he 'didn't care' and refused access. Sternheim threatens to notify the Judge of this violation and potential contempt of court.
EFTA00021709.pdf
An email thread from January 2021 regarding the delivery of legal discovery materials to Ghislaine Maxwell at the MDC. An Assistant US Attorney requested permission for Maxwell's defense counsel to hand-deliver a hard drive containing evidence because the prosecution could not deliver it before the weekend and FedEx was too slow. The request was denied by the recipient (likely an MDC official), who stated the materials must come directly from the US Attorney's office.
EFTA00021015.pdf
This document is a letter from defense attorney Bobbi C. Sternheim to Judge Alison J. Nathan regarding the conditions of Ghislaine Maxwell's detention at the MDC. Sternheim argues that Maxwell requires access to a laptop on weekends and holidays to review millions of pages of discovery materials because the standard prison computers are technically inadequate, slow, and prone to crashing. The letter also alleges mistreatment of Maxwell by MDC guards, including psychological and physical abuse, and highlights that Maxwell is isolated with no human contact other than guards.
EFTA00020978.pdf
This document is a chain of emails between Ghislaine Maxwell's defense counsel (Christian Everdell) and the US Attorney's Office regarding various discovery disputes in early 2021. Key issues include technical difficulties with Maxwell accessing discovery on prison computers, requests for unredacted FBI reports from 2006 found on Epstein's devices, and clarification regarding 'missing' pages from flight logs produced by pilot David Rodgers (which the prosecution explains were re-numbered/included in a different file). The defense also raises concerns about a Daily Beast article referencing a search warrant affidavit, which the prosecution confirms was unsealed by the court in New Hampshire, not leaked by their office.
EFTA00020899.pdf
This document is an email chain from October and November 2020 between USANYS officials discussing the procurement and configuration of a 'clean' laptop for Ghislaine Maxwell while she is detained at the MDC. The laptop is intended for her to review discovery materials due to accessibility issues, with the emailers noting a similar arrangement was made in the Avenatti case and confirming that the MDC warden had approved the request.
EFTA00020861.pdf
This document is an email chain from late September 2020 between members of a legal team regarding the 'Fourth Production' of discovery materials. Key topics include the technical handling of 'LSJ Scene2Go' (an application containing 3D maps of Little St. James, specifically the grotto and main structure), the processing of a JPMorgan document production, and the status of files related to 'Maxwell's MDC drive'. The team discusses strategies for Bates stamping viewable image files versus system files to ensure the defense can utilize the materials.
EFTA00020832.pdf
This document is an email dated November 9, 2020, from an Assistant US Attorney (SDNY) to Ghislaine Maxwell's defense team (Everdell, Cohen, Pagliuca, Menninger, Sternheim). The email notifies counsel that a hard drive containing new discovery production is available for pickup at One St. Andrew's Plaza and highlights a specific disclosure regarding a witness statement. It also confirms that copies of this and prior productions are being sent to the Metropolitan Detention Center (MDC) for Ms. Maxwell's review.
EFTA00020817.pdf
This document is an email chain from October 13-14, 2021, detailing the internal coordination at the US Attorney's Office (SDNY) regarding the 24th discovery production in the Ghislaine Maxwell case. The correspondence involves receiving 'spreadsheets from Denver exports' from an NYPD/FBI Task Force detective, stamping them with Bates numbers (SDNY_GM_02765031-2765061), and preparing them for transmission to defense counsel via USAfx and to the MDC (Metropolitan Detention Center) on a disc. A specific request was made to label the documents simply as 'Spreadsheets' rather than 'FBI Spreadsheets' in the index.
EFTA00020430.pdf
This document contains an email chain from March 29, 2021, between Ghislaine Maxwell's defense attorney, Christian Everdell, and the US Attorney's Office (USANYS). The correspondence details technical disputes regarding discovery materials, specifically the defense's inability to provide a hard drive to Maxwell in prison (MDC), issues with unreadable disks, missing email attachments, and discrepancies in metadata for over 110,000 files seized from Jeffrey Epstein's devices. The prosecution explains that some metadata is missing because files were 'carved or deleted' and offers solutions for transferring missing files.
EFTA00020426.pdf
This document is an email chain from March 2021 between Ghislaine Maxwell's defense counsel (Christian Everdell) and the U.S. Attorney's Office (SDNY) regarding discovery disputes. The defense raises seven specific issues, including the inability of Maxwell to view files on prison computers, missing email attachments (over 109,000), metadata discrepancies suggesting files were created/modified after seizure, and gaps in Bates numbering. The prosecution responds by explaining technical limitations with the MDC (prison), asserting that metadata reflects the state of files upon FBI seizure or carving, and clarifying that certain images came from physical CDs seized from Epstein's residences in 2019 rather than electronic extractions.
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