Defendant Ghislaine Maxwell was present with attorney Christian Everdell at the Pretrial Conference.
Christian Everdell is listed as an 'Attorney for Defendant Ghislaine Maxwell'.
Christian Everdell is listed as the filer of legal motions on behalf of Ghislaine Maxwell.
Document filed by Ghislaine Maxwell... (Everdell, Christian)
Everdell filing motions in support of Maxwell (Entries 210, 211, 212, 213)
Everdell files Reply Memorandums in support of Maxwell (Docs 285, 286, 287).
Memorandum of Law... (Everdell, Christian)
Listed as Defendant's Counsel
identified as one of her attorneys in the stipulation
Everdell files motion on behalf of Maxwell.
Listed as 'Attorneys for Defendant Ghislaine Maxwell'.
Listed as 'Attorneys for Defendant Ghislaine Maxwell'
Everdell filing motions on Maxwell's behalf
Listed as attorney for defendant Ghislaine Maxwell
defendant Ghislaine Maxwell, by and with the consent of her attorneys, Christian Everdell...
Listed as 'Attorneys for Defendant Ghislaine Maxwell'
Defendant Ghislaine Maxwell present with attorney... Christian Everdell
Everdell filing motions on behalf of Maxwell (Entry 223, 224, 225).
Listed as attorney for defendant
Defendant Ghislaine Maxwell present with attorney... Christian Everdell
defendant Ghislaine Maxwell, by and with the consent of her attorneys, Christian Everdell...
along with Christian Everdell... appearing for Ghislaine Maxwell
Listed as Counsel for Ghislaine Maxwell
Defendant Ghislaine Maxwell present with attorney... Christian Everdell
Motion filed by Ghislaine Maxwell. (Everdell, Christian)
Everdell filing motions on behalf of Maxwell (Entries 211, 212, 213).
Everdell files multiple memorandums of law in support of Maxwell.
Listed as Defendant's Counsel
Defendant Ghislaine Maxwell present with attorney... Christian Everdell
Minute entry states Maxwell present with attorney Christian Everdell.
Defendant Ghislaine Maxwell present with attorney... Christian Everdell
Letter addressed to Everdell regarding U.S. v. Ghislaine Maxwell
Everdell is part of the defense team coordinating evidence review.
Everdell is addressed as counsel in the case United States v. Ghislaine Maxwell.
Everdell refers to Maxwell as 'our client' and 'Ms. Maxwell'.
Everdell is cc'd on email regarding Maxwell.
Addressed as counsel for United States v. Ghislaine Maxwell
Everdell CC'd on attorney-client privilege correspondence.
Addressed as counsel in US v. Maxwell.
Everdell writes on behalf of Maxwell to secure discovery materials for her defense.
Addressed as counsel in US v. Ghislaine Maxwell
Everdell advocates for Maxwell's access to discovery materials.
Everdell files motions on behalf of Ms. Maxwell.
Refers to Maxwell as 'our client' and discusses her prison conditions.
Everdell refers to Maxwell as 'our client' and 'Ms. Maxwell'.
Everdell refers to Maxwell as 'our client' and 'Ms. Maxwell'.
Everdell refers to requesting images for 'Ms. Maxwell' and the AUSA refers to her as 'your client'.
Everdell writes on behalf of Maxwell regarding her access to discovery materials.
Email states Everdell is 'representing defendant Ghislaine Maxwell'
Everdell refers to Maxwell as 'our client' and 'Ms. Maxwell' and advocates for her access to discovery materials.
Frequent legal calls listed
Everdell refers to Maxwell as 'our client' and advocates for her access to discovery materials.
Addressed as counsel in US v. Ghislaine Maxwell
Everdell advocates for Maxwell's ability to review evidence on a hard drive.
Cc'd on legal correspondence regarding Maxwell.
Everdell submits motion on behalf of Maxwell.
Everdell sending email on behalf of Maxwell regarding her defense preparation.
Letter addresses Everdell regarding U.S. v. Ghislaine Maxwell
Email states Everdell is 'representing defendant Ghislaine Maxwell'
Everdell is filing bail motions on behalf of the defendant in U.S. v. Ghislaine Maxwell.
Everdell submits filings on behalf of Maxwell.
Everdell advocates for Maxwell's ability to review discovery materials on a hard drive at MDC.
Everdell listed as counsel for Maxwell case
Everdell is addressed as counsel for the defense in the case against Maxwell.
Everdell refers to sending 'our client' (Ms. Maxwell) a hard drive.
Letter addressed to Everdell regarding U.S. v. Maxwell
Everdell is addressed as counsel in the Maxwell case.
Addressed as Counsel in US v. Ghislaine Maxwell
Everdell is addressed as counsel for the case United States v. Ghislaine Maxwell
Everdell submits response on behalf of 'Ms. Maxwell' as her counsel from Cohen & Gresser.
Addressed as counsel in US v. Maxwell
Everdell is addressed as counsel for the defendant.
Addressed as counsel in U.S. v. Ghislaine Maxwell
Everdell sending emails on behalf of Maxwell regarding her defense preparation.
Refers to Maxwell as 'our client' and discusses logistics for sending her discovery materials.
Letter addressed to Everdell regarding United States v. Ghislaine Maxwell
Everdell is a recipient of the email regarding US v. Maxwell
Everdell listed as counsel in USA v. Maxwell emails and court notice.
Email states Everdell is 'representing defendant Ghislaine Maxwell'
Everdell advocates for Maxwell's access to discovery drives at the MDC.
Addressed as counsel in Re: United States v. Ghislaine Maxwell.
Everdell writes on behalf of Maxwell regarding her defense preparation.
Everdell is addressed as counsel in United States v. Ghislaine Maxwell.
Everdell attended legal visit with Sternheim.
Everdell is addressed as counsel for the defense in US v. Maxwell
Everdell filing motions on behalf of Maxwell.
Maxwell is represented by Christian Everdell...
Everdell is filing legal motions on behalf of Maxwell (implied by sender context and case subject).
EFTA00027663.pdf
This document contains an email chain from November 2021 regarding the criminal case U.S. v. Ghislaine Maxwell. Defense attorney Christian Everdell submits a response to the government's letters concerning 'Accuser-3's evidence' to Judge Nathan's chambers, filing the document under temporary seal to allow for potential redactions. The correspondence also lists other defense team members including Jeff Pagliuca, Laura Menninger, and Bobbi Sternheim.
EFTA00010133.pdf
This document is a discovery letter dated November 9, 2021, from U.S. Attorney Damian Williams to Ghislaine Maxwell's defense team. It details the production of 'SDFL Files' (likely Southern District of Florida files) with Bates numbers SDNY_GM_02767074 through SDNY_GM_02771980. The letter notes these materials are confidential under a protective order and appear to be duplicative of previous discovery.
EFTA00010162.pdf
A letter dated November 16, 2021, from US Attorney Damian Williams to Ghislaine Maxwell's defense team. The letter accompanies the production of Jencks Act and Giglio materials for potential trial witnesses, as well as materials related to individuals the government does not currently intend to call. It specifies that these materials are subject to a protective order and explains the specific labeling used to distinguish them from classified documents.
EFTA00010160.pdf
This document is a letter dated November 16, 2021, from U.S. Attorney Damian Williams to the defense counsel for Ghislaine Maxwell. It serves as a cover letter for the production of discovery materials, specifically AT&T records, phone records, and photographs, noting that these materials are subject to a protective order.
EFTA00011133.pdf
This document is a letter dated October 13, 2021, from U.S. Attorney Damian Williams to Ghislaine Maxwell's defense team. The Government asserts that Maxwell has waived her right to use an insanity or mental condition defense (Rule 12.2) because she failed to provide notice by the pretrial motion deadlines in early 2021. The letter demands that if the defense intends to use such evidence despite the waiver, they must provide notice by October 20, 2021.
EFTA00011259.pdf
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.
EFTA00031016.pdf
This document is a discovery letter dated May 3, 2021, from the U.S. Department of Justice (SDNY) to Ghislaine Maxwell's defense team. It accompanies the production of photographs (Bates range SDNY_GM_02753399 to SDNY_GM_02753431) designated as confidential under a Protective Order.
DOJ-OGR-00020536.jpg
This document is a docket sheet page from October 2021 regarding the case USA v. Ghislaine Maxwell. It details a pretrial conference held via telephone on October 21, 2021, attended by the defendant and legal teams. Significant entries include Judge Nathan's order (Doc 364) establishing jury selection protocols, denying a defense request to seal questionnaires, and addressing media opposition to secret proceedings filed by the Reporters Committee for Freedom of the Press.
EFTA00014650.pdf
A letter from the U.S. Attorney's Office (SDNY) to Ghislaine Maxwell's defense team dated November 20, 2021, accompanying a production of discovery materials. The production includes Jencks Act and Giglio materials for potential trial witnesses, as well as statements from individuals the government does not currently plan to call. The letter also clarifies labeling protocols for confidential documents under the Protective Order to avoid confusion with classified material.
EFTA00015636.pdf
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.
EFTA00015770.pdf
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.
EFTA00016768.pdf
This document is an email from attorney Christian Everdell of Cohen & Gresser LLP to Judge Nathan, dated December 19, 2020. It serves as a transmittal for filing a Renewed Bail Motion Reply Memorandum and accompanying exhibits under seal in the case U.S. v. Ghislaine Maxwell (20 Cr. 330). Other defense counsel, including Bobbi Sternheim, Jeff Pagliuca, and Laura Menninger, are copied on the correspondence.
EFTA00017813.pdf
This document is an email chain between Ghislaine Maxwell's defense counsel (Christian Everdell) and the US Attorney's Office (SDNY) regarding discovery production disputes in November 2020. The defense expresses significant frustration regarding technical issues with hard drives provided to Maxwell at the MDC, including broken drives and a lack of consolidation, as well as severe restrictions on the hours Maxwell is permitted to use a laptop to review over 2 million pages of evidence. The prosecution responds by offering to consolidate materials onto a single drive and explaining that the limited laptop access (8:30am-3:30pm) is due to MDC security protocols requiring lieutenant supervision.
EFTA00019092.pdf
This document is an email chain from March 2021 regarding discovery disputes in the Ghislaine Maxwell case. Defense attorney Christian Everdell outlines seven specific issues to the US Attorney's Office (USANYS), including technical problems with Maxwell accessing files on the prison computer, missing email attachments, and significant metadata discrepancies where files from Jeffrey Epstein's devices show creation/modification dates occurring after his death and the seizure of the devices (dates in 2020). The chain concludes with USANYS contractors scheduling an internal meeting to address these production issues.
EFTA00019420.pdf
A discovery letter dated December 16, 2020, from the U.S. Attorney's Office (SDNY) to Ghislaine Maxwell's defense team. The letter documents the production of materials designated as confidential, specifically referencing a 'UBS Subpoena Return' dated December 15, 2020. The document indicates ongoing discovery obligations and mentions that physical items are in FBI custody.
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.
EFTA00022052.pdf
A discovery production letter dated October 19, 2020, from the U.S. Attorney's Office (SDNY) to Ghislaine Maxwell's defense team. The letter outlines a production of evidence including FBI Florida and NY documents, Palm Beach Police Department (PBPD) materials, aerial video, and 3-D blueprints, spanning Bates numbers SDNY_GM_00328070 through SDNY_GM_00356148. The letter designates specific items as 'Confidential' or 'Highly Confidential' under a Protective Order.
EFTA00022511.pdf
A discovery letter from the U.S. Attorney's Office (SDNY) to Ghislaine Maxwell's defense team dated May 3, 2021. The letter confirms the production of confidential photographs (Bates range SDNY_GM_02753399 to SDNY_GM_02753431) under a Protective Order.
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.
EFTA00023360.pdf
This document is a letter dated November 20, 2021, from the U.S. Department of Justice to Ghislaine Maxwell's defense team regarding the production of discovery materials. The government provided Jencks Act and Giglio materials for potential trial witnesses, as well as witness statements for individuals they did not currently intend to call to testify. The letter also clarifies confidentiality designations under a Protective Order.
EFTA00023363.pdf
An email chain from November 20-21, 2021, between defense counsel Christian Everdell and Judge Alison Nathan's chambers in the case U.S. v. Ghislaine Maxwell. The correspondence concerns the filing of a redacted letter regarding the self-authentication of birth certificates for alleged minor victims. The Court instructs the defense to follow Docket No. 474 for filing instructions.
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.
EFTA00024887.pdf
This document contains email metadata from January 7, 2021, regarding Ghislaine Maxwell (referencing her inmate number 02879-509). The email was routed through the Federal Bureau of Prisons (BOP.GOV) system and addressed to her defense team, including Bobbi Sternheim, Christian Everdell, and Mark Cohen.
EFTA00025282.pdf
This document is an email chain from October 2021 detailing complaints by Ghislaine Maxwell's defense attorney, Bobbi Sternheim, regarding conditions at the MDC. Sternheim alleges 'foul play' or a 'cover-up' regarding legal mail that went missing and reappeared with USPS markings despite being placed in an internal mailbox. Additional complaints include inadequate space and COVID safety during legal visits, denial of requests to see the Warden, and issues with food (receiving meat while on a vegetarian diet) and electricity.
EFTA00027296.pdf
This document is a discovery production letter from the U.S. Attorney's Office (SDNY) to Ghislaine Maxwell's defense team, dated August 4, 2021. It lists produced materials including FBI recovered metadata, Missouri records, a JPMorgan Chase return, and a letter from 1995 related to Oxford. The letter also clarifies new labeling protocols for confidential materials to distinguish them from classified documents.
EFTA00027301.pdf
This document is a discovery production letter from the DOJ to Ghislaine Maxwell's defense team, dated August 5, 2021. It lists materials being turned over, including files recovered from discs seized at Jeffrey Epstein's New York residence, images from his electronic devices, Missouri records, a JPMorgan Chase return, and a 1995 Oxford letter. The letter also clarifies confidentiality designations under the Protective Order.
EFTA00027861.pdf
This document is an email chain from March 2021 between Ghislaine Maxwell's defense team (Cohen & Gresser LLP) and the US Attorney's Office (USANYS). The defense raises several technical discovery issues, including the inability of Maxwell to read discovery disks on the prison computer, missing email attachments, and corrupted metadata on files extracted from Jeffrey Epstein's devices (showing 2020 dates instead of original dates). The prosecution forwards these issues to their contractor (PAE) to address.
EFTA00027864.pdf
This document is an email chain from March 2021 between Ghislaine Maxwell's defense team (Cohen & Gresser) and US prosecutors (USANYS). The defense raises seven specific technical issues regarding discovery, including the need to provide evidence on hard drives rather than disks for the prison computer, over 100,000 emails missing attachments, and metadata discrepancies where files extracted from Jeffrey Epstein's devices show creation dates after his death (July 2020). The email also mentions videos from SDFL and PBPD investigations.
EFTA00028571.pdf
This document is a chain of email correspondence between Ghislaine Maxwell's defense team (Everdell, Menninger) and the US Attorney's Office (SDNY) regarding discovery disputes in Spring 2021. Key issues include the defense's inability to view certain files on prison computers, missing email attachments (over 109,000), and technical disputes over metadata for 'carved' or deleted files recovered from Jeffrey Epstein's electronic devices. The prosecution explains that metadata for deleted files was not recovered and that certain images (nude and non-nude) were seized from CDs in Epstein's residences rather than extracted by CART from devices.
EFTA00028646.pdf
This document is a chain of emails between Ghislaine Maxwell's defense team (Cohen & Gresser; Haddon, Morgan & Foreman) and the US Attorney's Office (SDNY) regarding discovery production disputes in Spring 2021. Key issues include technical difficulties Maxwell faced in reviewing digital evidence at the MDC prison (specifically reading disks vs. hard drives), missing attachments for over 109,000 emails, and metadata discrepancies for 'carved' or deleted files recovered from Jeffrey Epstein's devices. The correspondence details the logistical back-and-forth regarding file formats, USAfx transfers, and the potential need for judicial intervention (Judge Nathan) to force the MDC to accept specific hard drives.
EFTA00030569.pdf
This document is a formal response from the U.S. Attorney's Office (SDNY) to Ghislaine Maxwell's defense team regarding 22 specific discovery requests made on October 13, 2020. The government addresses requests for Epstein's diary, the 'Billionaires Playboy Club' manuscript, flight logs (implied in broader requests but not itemized), and the identities of minor victims, often denying immediate production based on Rule 16 restrictions or asserting that materials have already been produced. The letter also discusses the handling of potential 'Brady' and 'Giglio' materials, stating that impeachment evidence will be produced closer to trial.
EFTA00030861.pdf
This document is an email chain and legal correspondence between Ghislaine Maxwell's defense team (Cohen & Gresser) and the US Attorney's Office (SDNY) regarding discovery disputes in January 2021. Defense attorney Christian Everdell lists eight specific issues, including the urgent need for a hard drive for Maxwell to review evidence in prison, missing subscriber info for AT&T documents, and specifically noting that the first 27 pages of flight logs produced by pilot David Rodgers ('Rodgers000001-000027') were missing. The defense also inquires about a Daily Beast article referencing a cell-site simulator affidavit that they believe was not properly unsealed.
EFTA00031440.pdf
This document is a discovery production letter from the U.S. Attorney's Office for the Southern District of New York to Ghislaine Maxwell's defense team, dated April 14, 2021. It details the production of a single photograph (Bates number SDNY_GM_02753398) designated as 'Confidential' under a Protective Order. The letter is signed by U.S. Attorney Audrey Strauss, with the specific Assistant U.S. Attorneys' signatures redacted.
EFTA00032083.pdf
This document is an email chain from September 2, 2021, involving Ghislaine Maxwell's defense attorney, Bobbi C. Sternheim. Sternheim is formally notifying government officials (likely USANYS) of a breach in attorney-client privilege, stating that during a VTC session the previous day, Maxwell observed suspicious activity on the monitor which was also witnessed by an MDC Case Manager. Sternheim demands an explanation and remediation for this interference with the 'secure' Webex line.
EFTA00032722.pdf
An email chain from June 16, 2021, in which attorney Bobbi C. Sternheim lodges a formal complaint regarding conditions affecting her client, Ghislaine Maxwell. The complaints focus on technical issues in the VTC room hindering attorney-client communication and specific allegations of inappropriate, threatening, and mocking behavior by detention guards toward Maxwell.
DOJ-OGR-00020666.jpg
This document is a page from the SDNY court docket for the case against Ghislaine Maxwell, covering filings between May 14 and May 21, 2021. It details legal maneuvering regarding redactions to protect third parties and victims, as well as defense motions to suppress evidence obtained via subpoena and to strike surplusage from the indictment. Notably, it includes a judge's order admonishing the Metropolitan Detention Center (MDC) to ensure Maxwell's security protocols are necessary and neutral, and urging them to reduce sleep disruption.
EFTA00025035.pdf
A letter from the U.S. Attorney's Office (SDNY) to Ghislaine Maxwell's defense team regarding the production of Jencks Act and Giglio materials for potential trial witnesses. The letter clarifies a stamping error in a previous production (October 11, 2021) involving records 3501.507-516 and explains new labeling protocols for confidential materials to distinguish them from classified documents.
EFTA00023045.pdf
A discovery cover letter dated July 21, 2021, from the U.S. Attorney's Office (SDNY) to Ghislaine Maxwell's defense team. The letter accompanies the production of 'FedEx Records' (Bates range SDNY_GM_02753552 to SDNY_GM_02759392) which are designated as confidential under a protective order. The document outlines the ongoing discovery obligations of the government.
EFTA00024021.pdf
This document is an email chain from March 2021 related to the U.S. v. Ghislaine Maxwell case. Christian Everdell of Cohen & Gresser LLP submits reply memoranda and exhibits for pretrial motions to Judge Nathan's chambers and government prosecutors (USANYS), noting that documents are being filed under seal with redacted versions for the public docket.
EFTA00024562.pdf
This document is an email chain from July 6, 2020, between an Assistant United States Attorney (SDNY) and U.S. Pretrial Services. The correspondence concerns arranging a pretrial interview for defendant Ghislaine Maxwell with her attorneys, Christian Everdell and Mark S. Cohen, in preparation for her bail hearing later that week. Pretrial Services confirms they will handle the request.
EFTA00020434.pdf
This document is an email chain from March 2021 between Ghislaine Maxwell's defense team (Cohen & Gresser) and the US Attorney's Office. Defense attorney Christian Everdell outlines seven specific technical issues regarding discovery production, including the inability of Maxwell to view files on prison computers, missing email attachments, and corrupted metadata on over 110,000 documents extracted from Jeffrey Epstein's devices. The prosecution team discusses internally setting up a call with their vendor, PAE, to address these errors.
EFTA00020663.pdf
This document is an email chain dated July 14, 2020, providing a detailed log of legal calls made by Ghislaine Maxwell (USMS No. 02879-509) between July 6 and July 14, 2020. The sender forwards this list to ensure that 'Mark' (likely Mark Cohen or opposing counsel) does not misrepresent Maxwell's access to counsel during an upcoming hearing. The log details dates, times, durations, and participants of the calls, which primarily include attorneys Christian Everdell, Mark Cohen, Laura Menninger, and Jeff Pagliuca, as well as Lea Harmon from Pretrial Services.
EFTA00028585.pdf
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.
DOJ-OGR-00020713.jpg
This document is a court docket sheet from the case USA v. Ghislaine Maxwell, covering filings between February 11 and February 24, 2022. It details motions for a new trial filed by the defense, communications regarding redactions to protect juror anonymity (specifically Juror 50), and the granting of an amicus curiae brief. The document lists correspondence between the prosecution (USA), the defense team (Sternheim, Everdell), and Judge Alison J. Nathan.
EFTA00024907.pdf
This document is an email chain from November 2021 regarding the U.S. v. Ghislaine Maxwell trial. Defense attorney Christian Everdell submits a response to the court regarding the self-authentication of birth certificates for alleged minor victims. In an internal forward, a USANYS (prosecution) staff member notes that the defense has 'conceded' on the issue, prompting a colleague to reply 'Nice work!'.
EFTA00024564.pdf
An email chain from July 6, 2020, coordinating a pretrial interview for Ghislaine Maxwell. An Assistant U.S. Attorney introduces Maxwell's defense lawyers, Christian Everdell and Mark Cohen, to a U.S. Pretrial Services officer to arrange the interview ahead of a bail hearing scheduled for that week.
EFTA00030092.pdf
A cover letter from the U.S. Attorney's Office (SDNY) to Ghislaine Maxwell's defense team dated March 12, 2021. The letter accompanies a discovery production of photographs and documents received from victims not referenced in the indictment (S1 20 Cr. 330), designated as confidential under a protective order.
EFTA00030755.pdf
This document captures the metadata of an email sent by attorney Christian Everdell regarding the case U.S. v. Ghislaine Maxwell (20 Cr. 330). Dated December 8, 2020, the email conveys a 'Renewed Bail Motion and Exhibits' to be filed under seal. The email originated from the domain CohenGresser.com and was blind copied to a USAHUB address.
EFTA00015823.pdf
A letter from the U.S. Attorney's Office (SDNY) to Ghislaine Maxwell's defense team regarding 16 evidence discs labeled as 'Epstein Encase Files.' The government identified these discs as containing a forensic image of a computer seized from Epstein's Palm Beach residence in 2005. However, the government concluded that the original warrant authorized seizure but not the search of the computer's contents, and thus they lack the lawful authority to review the files or allow the defense to access them.
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.
EFTA00010180.pdf
A discovery letter from the U.S. Attorney's Office (SDNY) to Ghislaine Maxwell's defense team dated November 11, 2021. The letter details the production of 'Amazon records' (Bates SDNY_GM_02771981-02771983) which were sourced from the U.S. Attorney's Office for the Southern District of Florida and potentially duplicate materials previously produced from the Florida FBI file.
EFTA00021034.pdf
A letter from U.S. Attorney Damian Williams to Ghislaine Maxwell's defense counsel dated November 23, 2021, accompanying a discovery production. The production includes JPMC records, phone records, and other documents designated as confidential under a protective order. The letter clarifies labeling protocols for confidential materials to distinguish them from classified documents.
EFTA00010410.pdf
This document contains an email chain between defense attorney Christian Everdell and US Attorney's Office prosecutors (Lara Pomerantz, Maurene Comey, et al.) dated June 30, 2021, regarding the case USA v. Maxwell. The correspondence confirms that the defense has no redactions to propose regarding a court opinion and coordinates the filing of a joint letter to the court. The document also includes the official Notice of Electronic Filing (Order 305) from Judge Alison J. Nathan, which set the deadlines for these redaction proposals.
EFTA00029942.pdf
This document is an email chain from March 2021 involving Ghislaine Maxwell's defense team (Cohen & Gresser LLP) and the US Attorney's Office (USANYS). Attorney Christian Everdell raises seven specific discovery issues, including the inability of Maxwell to access files on disks via the prison computer, missing attachments for over 109,000 emails, and significant metadata discrepancies where files extracted from Epstein's devices show modification dates (July 2020) well after his death and device seizure. The email specifically requests metadata overlays to correct these issues and inquires about a gap in document production numbers.
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.
DOJ-OGR-00015539.jpg
This document is the signature page (page 3) of a legal stipulation from the trial of Ghislaine Maxwell, dated November 28, 2021. It confirms an agreement between the prosecution (Southern District of New York) and the defense team to admit specific Government Exhibits (1004, 11, 12, 13, 14, 15, and 16) into evidence. The document bears the signatures of Assistant US Attorneys and Maxwell's defense counsel.
EFTA00017768.pdf
An email dated July 6, 2020, from Assistant US Attorney Maurene (likely Comey) to redacted recipients, copying defense attorneys Christian Everdell and Mark S. Cohen. The email concerns arranging a pretrial interview for the attorneys with their client, Ghislaine Maxwell, prior to her upcoming bail hearing in case 20 Cr. 330 (AJN).
EFTA00030912.pdf
This document is an email chain from January 2021 between Ghislaine Maxwell's defense counsel (Cohen & Gresser) and the US Attorney's Office (SDNY) regarding various discovery disputes. Key issues include Maxwell's inability to access files on a CD at the MDC prison, requests for unredacted FBI reports from 2006, missing subscriber info in AT&T records, and clarification regarding missing pages from flight logs produced by pilot David Rodgers. The prosecution responds that the 'missing' Rodgers pages were produced in a separate file (SDNY_GM_00005650-5676) and confirms that a Daily Beast article referenced a document unsealed by a New Hampshire court, not leaked by the prosecution.
EFTA00031906.pdf
This document is an email chain from May 28, 2021, regarding the case U.S. v. Ghislaine Maxwell. Defense attorney Christian Everdell of Cohen & Gresser LLP emailed Judge Nathan's chambers to submit Ms. Maxwell's Omnibus Reply Memorandum in support of supplemental pretrial motions related to the S2 Superseding Indictment. The memorandum was filed under seal, while the cover letter was filed publicly. The email was subsequently forwarded internally within the US Attorney's Office (USANYS).
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This document is a page from a legal filing (Case 1:20-cr-00330-PAE) dated October 22, 2021, containing proposed voir dire questions (21-25) for the jury selection in the trial of Ghislaine Maxwell. It lists the specific legal teams for both the defense (led by Everdell, Menninger, Pagliuca, Sternheim) and the prosecution (led by US Attorney Damian Williams and AUSAs Comey, Moe, Pomerantz, Rohrbach). The document includes margin comments highlighting a dispute between the prosecution and defense regarding whether to refer to Maxwell as 'the defendant' or 'the accused'.
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This document is a docket sheet from the SDNY court case regarding Ghislaine Maxwell, covering filings from April 16 to April 19, 2021. It details various motions to dismiss and suppress evidence filed by Maxwell's defense team, orders from Judge Alison J. Nathan setting an arraignment date for April 23, 2021, and procedural orders regarding the severance of perjury counts and the handling of redacted documents. The document highlights the legal maneuvering regarding the S2 Superseding Indictment and disputes over evidence obtained via subpoena.
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This document is a court docket sheet from the Southern District of New York covering proceedings related to the sentencing of Ghislaine Maxwell in late June 2022. It records Judge Nathan's orders permitting specific victims (Annie Farmer, Kate, Virginia Giuffre, Sarah Ransome, Teresa Helm, and Elizabeth Stein) to read oral statements at sentencing, noting that Giuffre's counsel would read hers due to a medical issue preventing Giuffre's physical presence. The document also records the sentencing hearing held on June 28, 2022, listing the attorneys present for both the defense and the prosecution, and grants a motion by the NY Times Company to unseal juror questionnaires.
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This document is a legal stipulation in the case of USA v. Ghislaine Maxwell, agreeing to the admissibility of Palm Beach County School records. It confirms that witness Dominique Hyppolite would verify the records' authenticity and identifies specific exhibits (DH-1, DH-2, DH-3, J-2) related to a redacted individual and a witness identified as 'Jane'. The document itself is marked as Defense Exhibit DH-4.
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This document is a transcript from a pretrial conference held on December 8, 2021, for the case United States v. Ghislaine Maxwell. Judge Alison J. Nathan presides over the session, with legal teams for both the government (led by Maurene Comey) and the defense (led by Bobbi C. Sternheim) introducing themselves. The primary purpose of the conference is to discuss the logistics of jury selection (voir dire) and review lists of prospective jurors based on questionnaires administered in November.
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This document is a court docket page (Page 31 of 92) listing entries from April 16 to April 19, 2021, in the case against Ghislaine Maxwell. It details several filings by Maxwell's defense team (Everdell, Menninger, Pagliuca) including motions to dismiss counts of the superseding indictment and suppress evidence. Key orders by Judge Alison J. Nathan schedule an arraignment for the S2 Superseding Indictment for April 23, 2021, at the Daniel Patrick Moynihan Courthouse, sever perjury counts for a separate trial, and request government intent regarding the use of disputed subpoenaed documents.
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This document is a page from the court transcript of the trial *United States v. Ghislaine Maxwell* (Case 1:20-cr-00330-AJN), dated August 10, 2022. Defense attorney Mr. Everdell presents stipulations agreed upon by both parties, including the birth date of Mike Wallace and the opening dates of *The Lion King* on Broadway. The page concludes with the beginning of a written stipulation regarding a witness named 'Kate' attending a meeting with prosecutors in September, listing the full legal teams for both the prosecution (US Attorney's Office) and the defense.
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This document is a Criminal Notice of Appeal (Form A) filed on January 11, 2021, in the United States District Court for the Southern District of New York regarding the case United States v. Ghislaine Maxwell (Docket No. 1:20-CR-00330). Ghislaine Maxwell, represented by Christian Everdell of Cohen & Gresser LLP, is appealing the 'Order Denying Defendant's Renewed Motion for Release on Bail' which was entered on December 28, 2020. The document indicates Maxwell's bail disposition is 'Committed' (incarcerated) and lists Maurene Comey as the Assistant U.S. Attorney.
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This document is a legal stipulation from the case United States v. Ghislaine Maxwell (S2 20 CR 330). It represents an agreement between the prosecution and defense regarding the authenticity of UK land registry records. Specifically, it validates records retrieved in 2021 concerning properties at 69 Stanhope Mews East and 44 Kinnerton Street in London, with one record dating back to ownership confirmation in January 1994.
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This legal document is a stipulation dated December 10, 2021, from a case in the Southern District of New York. It is an agreement between the U.S. Attorney's office, represented by Damian Williams, and the attorneys for defendant Ghislaine Maxwell. The parties agree that 'Government Exhibit 1009' can be admitted as evidence at trial.
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This document is a court docket entry from February 28, 2023, for Case 22-1426, primarily concerning Ghislaine Maxwell. It details court orders and filings from November 2021, including COVID-19 protocols for courthouse access, scheduling revisions for motions in limine, and a pretrial conference. The entries highlight communications between the prosecution (USA) and defense (Ghislaine Maxwell's attorneys) regarding trial logistics and a ruling on witness testimony, all overseen by Judge Alison J. Nathan.
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This document is a page from a court docket (Case 22-1426) detailing filings and orders between April 20 and April 21, 2021, in the case of USA v. Ghislaine Maxwell. Key entries include Judge Nathan questioning the defense on whether they are seeking to adjourn the July 12th trial date, potentially until January 2022, and demanding a specific justification if so. The docket also covers disputes over redactions involving Boies Schiller Flexner LLP and motions to dismiss the indictment based on a Non-Prosecution Agreement.
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This document is a court docket sheet from the trial of Ghislaine Maxwell (Case 22-1426) covering proceedings from December 16 to December 18, 2021. It details minute entries for the jury trial, orders regarding witness testimony and jury charges, and correspondence between the prosecution (USA) and defense regarding prior inconsistent statements and jury instructions. Notably, it records the court's edits to the jury charge, specifically changing the definition of 'a minor' to 'an individual under the age of 18'.
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This document is a legal stipulation from the trial of United States v. Ghislaine Maxwell, dated December 17, 2021. It records an agreement between the prosecution (SDNY) and the defense to admit specific exhibits (MG-12, MG-1, 610-A, and A-5) into evidence. The document bears signatures from both the Assistant United States Attorneys and Maxwell's defense counsel.
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This document is a Criminal Notice of Appeal (Form A) filed on January 11, 2021, in the United States District Court, Southern District of New York. Ghislaine Maxwell, represented by attorney Christian Everdell, is appealing an order entered on December 28, 2020, which denied her renewed motion for release on bail. The document notes that Maxwell is currently 'Committed' (incarcerated) and the case is presided over by Judge Alison J. Nathan.
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This is a legal stipulation in the case United States v. Ghislaine Maxwell (S2 20 CR 330). Both the prosecution and defense agree that on August 17, 2021, attorney Robert Glassman told a prosecutor that he had previously advised his client, a witness known as 'Jane', to cooperate because it was 'morally right' and would 'help her case.' This document is marked as Defendant's Exhibit A-6.
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This document is a page from the court transcript of the trial of Ghislaine Maxwell (Case 1:20-cr-00330-PAE), filed on August 10, 2022. It details a stipulation agreed upon by the prosecution and defense regarding the testimony of Sergeant Michael Dawson to avoid recalling him to the stand. Defense attorney Christian Everdell reads the stipulation into the record, which concerns a cardboard box (Government Exhibit 294) recovered during a search.
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This document is a signature page from a legal stipulation dated December 6, 2021, in the trial of Ghislaine Maxwell. It confirms that 'Defendant's Trial Exhibit B' is agreed to be received in evidence. The document is signed by Maxwell's defense team (Everdell, Menninger, Pagliuca, Sternheim) and the prosecution team from the Southern District of New York (Comey, Moe, Pomerantz, Rohrbach).
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This document is a court docket report (Case 22-1426, SDNY) from November 2021 details legal proceedings in the US v. Ghislaine Maxwell case. It lists various filings including orders on redactions to protect victim privacy, motions in limine regarding 'Accuser-3' and co-conspirator statements, and a dispute over an unauthenticated hearsay document (Exhibit 52). The docket reflects active pre-trial litigation between the prosecution (AUSAs Comey, Moe, Pomerantz, Rohrbach) and defense counsel (Pagliuca, Everdell) regarding the admissibility of evidence and pseudonym logistics.
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This document is a docket report from the SDNY regarding the trial of Ghislaine Maxwell, detailing events from December 15 to December 17, 2021. It records minute entries for the jury trial held on December 16, 2021, listing all present attorneys for the defense and prosecution. The document also details various court orders regarding the admissibility of witness testimony (specifically mentioning Dr. Loftus and Alexander Hamilton) and procedural disputes over prior inconsistent statements.
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This document is a court docket page from June 2022 detailing the final proceedings leading up to and including the sentencing of Ghislaine Maxwell. It records orders permitting specific victims (including Virginia Giuffre and Annie Farmer) to present impact statements, notes Giuffre's absence due to medical issues, and confirms the sentencing hearing took place on June 28, 2022. It also includes an order granting the NY Times' motion to unseal juror questionnaires.
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This document is a page from the court docket for United States v. Ghislaine Maxwell, covering filings and orders between May 10, 2022, and June 21, 2022. It details pre-sentencing motions, including a denied request for an extension by the defense and granted motions regarding Speedy Trial Exclusion. Significant entries include logistical orders for the June 28, 2022 sentencing hearing and strict protocols for victim impact statements under the Crime Victims Rights Act.
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This document is a court docket sheet for the case against Ghislaine Maxwell, covering proceedings from September 1, 2021, to October 13, 2021. Key entries include Judge Nathan ordering the government to disclose the identities of unnamed co-conspirators, scheduling jury selection for November 19, and various filings regarding redactions and voir dire procedures. The document highlights the logistical preparations for the trial, including scheduling around the Christmas holidays.
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This document is a court docket sheet from the trial of United States v. Ghislaine Maxwell, covering proceedings from November 24, 2021, to November 30, 2021. It details the start of the jury trial on November 29, 2021, various filings regarding jury instructions and expert testimony (Dr. Ryan Hall), and orders related to materials from the Epstein Victims Compensation Program. The document also notes a court order granting a government request to seal filings to protect the privacy of anticipated witnesses.
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This document is a court docket from October 29, 2021, in the case against Ghislaine Maxwell, detailing numerous pre-trial motions in limine filed by her defense team. The motions aim to exclude various forms of evidence, including testimony about an alleged flight, items from a 2005 search, and any mention of an alleged 'Rape' by Jeffrey Epstein. The docket also records the prosecution's (USA) formal opposition to these motions, illustrating the legal strategies employed by both sides before the trial.
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This document is a court docket sheet from the case USA v. Ghislaine Maxwell, covering entries from October 27 to October 29, 2021. It details numerous 'motions in limine' filed by Maxwell's defense team (Pagliuca, Everdell) attempting to exclude specific evidence, including items seized from Epstein's Palm Beach home (358 El Brillo Way) in 2005, evidence related to 'Accuser-3', and an alleged flight. The document also records an order from Judge Nathan scheduling an in-person pretrial conference for November 1, 2021.
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This is the final signature page (page 17 of 17) of a legal filing in the case United States v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE). The page contains proposed jury instructions (Paragraph 67) regarding the prohibition of electronic communications and social media usage by jurors during the trial. It is signed by the prosecution team (US Attorney's Office) and the defense counsel for Ghislaine Maxwell, dated October 11, 2021.
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This document is a court docket log from the case USA v. Ghislaine Maxwell (Case 22-1426) covering April 16-19, 2021. It details various filings including defense motions to dismiss indictments and suppress evidence (specifically mentioning 'Martindell' issues and protective orders), and orders from Judge Alison J. Nathan scheduling an arraignment for the S2 Superseding Indictment. The document also notes the scheduling of separate trials for perjury and non-perjury counts.
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