This document is an email chain from July 17, 2020, between defense counsel (Christian Everdell and Laura Menninger) and government prosecutors regarding the case of Ghislaine Maxwell (referred to as 'GM' in attachments). The defense provides a proposed Protective Order and argues for specific terms, including the removal of a 'Highly Confidential' designation and the provision of a laptop to Maxwell in the MDC (Metropolitan Detention Center) so she can review discovery materials, as in-person legal visits were not allowed at the time. The email emphasizes the defense's desire to avoid trying the case in the press and cites concerns about witness harassment.
An email from Ghislaine Maxwell's defense team (likely to prosecutors/USANYS) dated December 30, 2020, complaining about conditions at the MDC. The email disputes MDC Legal's claim that Maxwell is not being directed to stand in specific spots, alleging guards enforced strict positioning rules under threat of sanction on December 29. The email also raises issues about Maxwell not receiving menu-designated food and technical failures with discovery discs on the MDC computer.
An email from attorney Bobbi Sternheim to redacted officials regarding Ghislaine Maxwell's confinement conditions at MDC. The email requests permission for Maxwell to use a laptop for reviewing discovery due to technical limitations of MDC computers and outlines several grievances, including invasive surveillance, freezing cell conditions, removal of bedding, excessive searches, and failure to deliver mail.
This document is an email chain between US Attorneys regarding a judicial inquiry into why Ghislaine Maxwell (at MDC) received significantly better legal access than Justin Rivera (at MCC). Judge Engelmayer called the disparity 'terrible' optics. The BOP's explanation was that Maxwell's protective custody status (isolation) allowed her exclusive use of equipment, whereas Rivera was in the general population sharing limited resources with ~80 other inmates. The emails track the drafting of a declaration to explain this to the court by the December 31, 2020 deadline.
An email thread from August 2021 between Ghislaine Maxwell's attorney, Bobbi Sternheim, and likely MDC or prosecution officials. Sternheim reports a security breach where third parties accessed a Zoom room during privileged attorney-client communication and requests a return to WebEx. The respondent denies a breach occurred, attributing the issue to an internal miscommunication where a secure line was already in use.
An email dated August 22, 2021, discussing a draft letter to Judge 'AJN' (likely Alison J. Nathan) regarding Ghislaine Maxwell's complaints about VTC (Video Teleconference) access at the MDC (Metropolitan Detention Center). The sender notes a deadline of the following day and mentions coordinating with MDC legal counsel for review.
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.
This document is a chain of emails between Ghislaine Maxwell's defense team (Cohen & Gresser) and the US Attorney's Office regarding discovery disputes. Key issues include the logistics of providing electronic discovery to Maxwell in prison (MDC) because she cannot use disks, missing email attachments, and metadata discrepancies for thousands of files and photos recovered from Epstein's devices and residences. The prosecution explains that 'carved' or deleted files lack original metadata and that certain photos came from seized CDs rather than devices processed by the FBI's CART unit.
An email from an Assistant US Attorney in the Southern District of New York to the legal defense team of Ghislaine Maxwell (including Christian Everdell and others) dated October 8, 2021. The email serves as notification for an additional discovery production in the case US v. Maxwell (20 Cr. 330) and discusses logistical arrangements for providing digital evidence to Ms. Maxwell at the Metropolitan Detention Center (MDC).
This document contains an email chain from November 20, 2021, between the U.S. Attorney's Office (SDNY) and defense counsel for Ghislaine Maxwell (Laura Menninger and Jeff Pagliuca). The correspondence concerns the logistics of discovery production, including the shipment of hard drives containing witness materials to counsel in Colorado and to Maxwell at the MDC, as well as clarifications regarding Bates numbering errors. The emails provide specific FedEx tracking numbers for the shipments.
This document is an internal email chain within the US Attorney's Office for the Southern District of New York (USANYS) from December 2020. It discusses a legal issue raised by Judge Engelmayer in the case of *United States v. Rivera*, where the judge criticized the Bureau of Prisons (BOP) for providing significantly better access to counsel and electronic discovery to Ghislaine Maxwell (at MDC) compared to Justin Rivera (at MCC). The emails detail the drafting of a declaration to explain that Maxwell's privileges (such as 13 hours/day of laptop access) are due to her unique protective custody status and the massive volume of discovery in her case, whereas Rivera is in the general population with shared resources.
This document is an internal email chain within the US Attorney's Office (SDNY) regarding a legal issue raised by Judge Engelmayer in the case *United States v. Rivera*. The Judge criticized the disparity between the extensive discovery and counsel access provided to Ghislaine Maxwell at MDC Brooklyn (91 hours/week laptop access) versus the limited access provided to Justin Rivera at MCC New York (21 hours/week). The emails discuss drafting a declaration to explain that these differences are due to Maxwell's unique protective custody status and facility capabilities, rather than preferential treatment based on class or race.
This document is an email chain dated December 30, 2020, between Ghislaine Maxwell's defense team and the US Attorney's Office (SDNY). The defense attorney alleges that MDC guards improperly instructed Maxwell not to stand in various parts of her isolation cell under threat of sanction, contradicting previous assurances from MDC Legal. The email also raises issues regarding food quality and technical failures with a discovery disc provided to Maxwell.
This document contains an email exchange dated December 30, 2020, between an Assistant US Attorney (SDNY) and Ghislaine Maxwell's defense team. The defense attorney complains that contrary to MDC Legal's claims, Maxwell is being subjected to strict movement restrictions within her isolation cell by guards, specifically regarding where she can stand. The email also raises issues about Maxwell not receiving menu-designated food and technical failures with a discovery disc on the MDC computer.
This document is an email dated April 29, 2021, from an Assistant United States Attorney (SDNY) to Judge Nathan's chambers regarding the case US v. Maxwell (Ghislaine Maxwell). The email transmits a letter from the Metropolitan Detention Center (MDC) legal counsel in response to a court order from earlier that day, noting that the letter was not filed electronically because the MDC is not a formal party to the case.
This document is an email chain from April 29, 2021, involving the US Attorney's Office for the Southern District of New York regarding the Ghislaine Maxwell case. It discusses an order issued by Judge Nathan directing the Metropolitan Detention Center (MDC) to take specific actions by April 30, 2021. The emails coordinate the filing and transmission of this order to the Judge's chambers.
This document is an email chain initiated by Bobbi C. Sternheim, counsel for Ghislaine Maxwell, addressed to prison officials (MDC) and forwarded to the US Attorney's Office (USANYS). Sternheim alleges that Maxwell was physically mistreated during a body search, specifically claiming a guard groped her breast, while another threatened her with assault charges. The letter explicitly links the BOP's handling of Maxwell to the negligence surrounding Jeffrey Epstein's death in the MCC.
Court order from April 2019 in the case of United States v. Nicholas Tartaglione (Epstein's future cellmate). Judge Kenneth Karas orders the Bureau of Prisons to withhold attorney work-product and legal visitation logs from federal prosecutors to protect the defendant's legal strategy. The order applies to the MCC, MDC, and potential transfer facilities like Westchester County Correctional Facility.
An email chain from January 2021 between the US Attorney's Office (SDNY) and redacted recipients regarding discovery materials for Ghislaine Maxwell. The prosecution explains that Maxwell could not view materials provided on CD, so a new drive was prepared. Due to logistical constraints, the AUSA asks for permission to allow defense counsel to hand-deliver the drive to the Metropolitan Detention Center (MDC) so Maxwell can review it over the weekend.
A letter from Ghislaine Maxwell's defense counsel (Cohen & Gresser) to the US Government prosecutors complaining about the government's failure to provide readable discovery materials at the MDC. The letter highlights that the government holds approximately 40,000 non-nude and thousands of nude/partially nude images seized from Jeffrey Epstein's properties in New York and the Virgin Islands. The defense requests a fully readable laptop for Maxwell and immediate access to the seized images, noting that COVID-19 restrictions complicate the review process.
This document is an email chain between Ghislaine Maxwell's defense team (Cohen & Gresser) and the US Attorney's Office (SDNY) regarding discovery disputes in early 2021. Key issues include technical difficulties providing Maxwell with discovery materials at the MDC (CDs vs. Hard Drives), a request for an unredacted 2006 FBI report found on Epstein's devices, and missing pages from flight logs produced by pilot David Rodgers (specifically pages 1-27). The defense also questions the government about a Daily Beast article referencing a 'newly unsealed' affidavit regarding a cell-site simulator used to track Maxwell.
This document is an email dated August 5, 2020, from an Assistant U.S. Attorney in the Southern District of New York. The email discusses the logistics and protocols for delivering a hard drive containing legal discovery materials to Ghislaine Maxwell, who is incarcerated at the MDC (Metropolitan Detention Center). The sender clarifies requirements regarding drive encryption and passwords.
This document is an email chain from December 2020 between the U.S. Attorney's Office for the Southern District of New York and likely MDC staff. It concerns the logistical replacement of a hard drive provided to Ghislaine Maxwell, which she had reportedly dropped and broke. The U.S. Attorney's office arranged for a replacement to be FedExed and requested the return of the broken unit.
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'.
This document is an email dated November 16, 2021, from an Assistant United States Attorney (SDNY) to the defense counsel for Ghislaine Maxwell (Everdell, Sternheim, Menninger, Pagliuca). The email serves to notify the defense of an additional discovery production, including testifying and non-testifying witness materials, sent via USAfx. It also notes that a hard drive provided by the defense will be sent to the MDC for Ms. Maxwell's use.
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