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Correspondence · May 12, 2021

Email from Maxwell's defense counsel to the judge filing a Rule 17 response

Maxwell's defense counsel transmits to the judge a letter response to the government's Rule 17 submission, filed under seal due to confidentiality.Machine-written summary

From: “:3’
To: Laura MenningerJeff Pagliuca
BOBBI C STERNHEIM“‘BOBBI C STERNHEIM‘“
le,
<
Christian Everdell
Cc:
Subject: FW: US v. Maxwell - 20 Cr. 330 (MN) - Response to Government’s Rule 17 Submission
Date: Thu, 13 May 2021 15:54:22 +0000
Attachments: 2021.05.12 JSP_Ltr._re._Response_to_Subpoena.pdf; EX.A.pdf; EX._B.pdf

Counsel,

In this filing, you represent that you have made multiple “attempts to confer with the government” regarding particular photographs referenced in our May 6, 2021 letter on this issue, and you further represent that those attempts “have gone unanswered for days.” Our team is not aware of any communications we have received from you attempting to confer about this particular issue between May 6, 2021 and May 12, 2021. Would you please either point us to the relevant communication, or correct this representation to the Court?

Thank you,

Assistant United States Attorney Southern District of New York

From: Laura Menninger ‹
>
Sent: Wednesday, May 12, 2021 9:03 PM
To: Nathan NYSD Chambers ‹>
Cc: ‘Bobbi Sternheim (>;• Jeff Pagliuca

Subject: US v. Maxwell - 20 Cr. 330 (AJN) - Response to Government’s Rule 17 Submission

Judge Nathan:

Attached please find Ms. Maxwell’s Letter Response to the government’s submission on the Rule 17 subpoena items 9-11, and Exhibits A and B.

Because Exhibit B was a document marked “Confidential” by the government pursuant to the Protective Order, we are compelled to file this under seal, pending any contrary order by the Court. We are prepared to file the Letter Response and Exhibits on the public docket at the Court’s direction.

Respectfully submitted,

Laura A. Menninger Laura A. Menninger I Partner Haddon Mor an & Foreman, P.C.

EFTA00014670

Email from Maxwell's defense counsel to the judge filing a Rule 17 response

Emails and letters

Maxwell's defense counsel transmits to the judge a letter response to the government's Rule 17 submission, filed under seal due to confidentiality.

DOJ Epstein Files, Data Set 8 · May 12, 2021

| From: " | :3' | | |--------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------|--| | To: Laura Menninger | Jeff Pagliuca | | | BOBBI C STERNHEIM | "'BOBBI C STERNHEIM'" | | | le,<br < | Christian Everdell | | | Cc: | | | | | | | | Subject: FW: US v. Maxwell - 20 Cr. 330 (MN) - Response to Government's Rule 17 Submission | | | | Date: Thu, 13 May 2021 15:54:22 +0000 | | | | | Attachments: 2021.05.12 JSP Ltr. re. Response to Subpoena.pdf; EX. A .pdf; EX. B.pdf | | Counsel, In…