Assistant United States Attorney (Redacted)
PersonRelationship Network
| Connected Entity | Relationship Type |
Strength
(mentions)
|
Documents | Actions |
|---|---|---|---|---|
|
person
Laura Menninger
|
Opposing counsel |
2
|
2 | |
|
person
CHRISTIAN EVERDELL
|
Opposing counsel |
2
|
2 | |
|
person
Redacted Recipient
|
Business associate |
2
|
2 | |
|
person
Recipient
|
Professional investigative |
1
|
1 | |
|
person
Clara Moran
|
Professional collaborative |
1
|
1 | |
|
person
USANYS Staff (Redacted)
|
Business associate |
1
|
1 | |
|
person
FBI Analyst (Redacted)
|
Professional collaboration |
1
|
1 | |
|
person
Jeff Pagliuca
|
Opposing counsel |
1
|
1 | |
|
person
Martin G. Weinberg
|
Opposing counsel |
1
|
1 | |
|
person
FBI
|
Legal representative |
1
|
1 | |
|
person
Redacted Recipient (USANYS)
|
Legal representative |
1
|
1 | |
|
person
CHRISTIAN EVERDELL
|
Legal representative |
1
|
1 | |
|
person
Laura Menninger
|
Legal representative |
1
|
1 |
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.
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.
EFTA00027949.pdf
This document is an email chain between attorney Jack Scarola and an Assistant United States Attorney (SDNY) regarding the prosecution of Jeffrey Epstein. Scarola identifies a victim who was molested in Florida beginning at age 14 and received lingerie gifts from Epstein. The correspondence coordinates a potential meeting between federal investigators and the victim in Florida.
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.
EFTA00024287.pdf
This document is an email chain from October 2019 between Sigrid McCawley (Boies Schiller Flexner) and an Assistant US Attorney (SDNY) coordinating interviews for several Epstein victims. The correspondence discusses scheduling around a 'victims' meeting' on October 23, 2019, and visa/passport issues for a specific victim who was 'brought to the US by Epstein a number of times.' The emails also mention a set of sisters, one of whom had already been interviewed by the SDNY.
EFTA00021994.pdf
This document is an email chain from June 2021 between an Assistant US Attorney (SDNY) and a likely bank representative regarding JPMC account documents for Jeffery Epstein and Ghislaine Maxwell. The correspondence provides a summary table listing Maxwell's roles (President, Treasurer, Authorized Signer) for various entities including Hyperion Air, Freedom Air, and JEGE Inc. It also details a specific transaction from October 1999 where $18.3 million was transferred to Maxwell from the Financial Trust Company account, sourced from the sale of a JP Morgan money market fund.
EFTA00021532.pdf
This document is an email chain from August 2, 2019, between the US Attorney's Office (SDNY) and Defense Counsel regarding the Jeffrey Epstein case. The correspondence details a dispute over whether specific discovery materials, including statements to law enforcement and cell site data, should be filed under seal or publicly with redactions. The prosecution accuses the defense of violating a protective order by publicly filing sensitive exhibits, while the defense discusses logistical issues regarding getting the defendant's affidavit signed at the MCC without the legal team acting as witnesses.
EFTA00021434.pdf
This document is a series of emails from July 2019 between defense attorney Michael Bachner and the SDNY/FBI regarding the Epstein investigation. The correspondence coordinates a 'reverse proffer' meeting where the government intends to persuade Bachner's female client to cooperate to avoid potential arrest. Bachner explicitly notifies the government that his client intends to invoke her Fifth Amendment privilege if called to testify before a Grand Jury.
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.
US v. Maxwell, 20 Cr. 330 (AJN)
Submission of proposed redactions to voir dire transcripts.
Jury instructions letter
Sender attaches a draft letter regarding jury instructions/limiting instructions and asks for comments.
witness travel
Request to arrange travel for a witness in the Maxwell case who will testify under a pseudonym.
Limiting instructions letter
Discussing a response to Judge Nathan regarding proposed limiting instructions related to an order on MV-3 (likely Minor Victim 3). The sender mentions drafting two responsive letters and asks to discuss it on a call.
US v. Maxwell, 20 Cr. 330 (AJN)
Submission of a letter motion temporarily under seal regarding the US v. Maxwell case.
Opening
Sender attaches an updated draft of the opening statement (Maxwell_Opening_v5.docx) reflecting comments from colleagues. Mentions adjusting the structure of the 'pyramid scheme' argument and requests a discussion the following day.
17(c) letter
Sender attaches a 17(c) letter and Motion to Quash. Mentions upcoming voir dire and plans to send the document to a redacted party at 8:30 if colleagues don't review it first.
Motion to quash
Sender attaches a draft motion to quash a defense subpoena for review by 'Chiefs'.
RE: Redaction
Submitting corrected version of Dkt. No. 453 with added redaction covering a name on page 11.
Redaction
Alerting Chambers that Dkt. No. 453 contains a redaction error revealing a witness name and requesting removal from ECF.
US v. Maxwell, 20 Cr. 330 (AJN)
Notification of additional discovery production via USAfx and delivery of a hard drive to MDC for Ms. Maxwell.
Second Daubert Motion
Sender attaches a second Daubert motion (Motion_to_preclude_Hall_et_al_v3.docx) for review, noting it is due the following day.
RE: Maxwell trial fact witness travel - [Redacted]
Requesting travel arrangements for a fact witness to fly in 12/8 and out 12/10 for testimony.
travel request
Requesting travel arrangements for a trial witness who needs a high floor hotel room to work remotely.
Paul Kane Q&A
Sender attaches a draft Q&A for Paul Kane. Discusses legal strategy regarding the admissibility of records not created by 'PCS' but maintained by them, citing United States v. Kuthuru. Suggests chatting about another hearsay issue.
United States v. Ghislaine Maxwell, 20 Cr. 330
Submission of attached letter (unredacted and with proposed redactions) and exhibit GX-52 to be filed under seal.
CC letter
Final version attached. Anyone want to review again before I file?
Monday
Request to create a binder for a court appearance on Monday containing attached legal documents.
US v. Maxwell, 20 Cr. 330 (AJN) - Letter Motion
Submission of an unredacted copy of the Government's letter motion (Dkt. No. 455) and a copy with proposed redactions.
Re: witness travel
Requesting a call to discuss trial witnesses traveling for the Maxwell case and wanting to 'flag a few things'.
Amazon return
Request to add attached Amazon subpoena return files to the Discovery folder.
US v. Maxwell, 20 Cr. 330 (AJN)
Notification of supplemental production of testifying witness material and exhibits for tomorrow's hearing.
[Redacted]
Requesting the most recent scan of a specific proffer agreement updated as of 9/21, mentioning it should be in the 'para file' if not on shared drive.
United States v. Maxwell, 20 Cr. 330, juror questionnaires
Submission of a joint letter regarding prospective juror questionnaires.
bridge
Discussing logistics for bridge access for upcoming hearing and jury selection.
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