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Correspondence · Oct. 29, 2021

Email chain among Maxwell trial counsel on redactions to motions in limine, Oct 2021

Email chain between SDNY prosecutors and defense counsel coordinating redactions, sealing, and filing of motions in limine and exhibits ahead of trial.Machine-written summary

</ceverdell<>
From: ‘
To: Christian Everdell <ceverdell< td="">CohenGressencom>, ”CohenGressencom>, ”
, BOBBI C
STERNHEIM bcsternheim@mac.com, Laura Menninger imenninger@hmflaw.com,/imenninger@hmflaw.com/bcsternheim@mac.com
Jeff Pagliuca ipagliuca®hmflaw.com>
Cc:
Subject:RE: Redactions: Government motion in limine
Date:Sat, 30 Oct 2021 00:11:41 +0000
Attachments:2021-10-29_Govit_letter_re_Proposed_Redactions_to_MILs_vl.docx

Thanks, Chris. I know you’re in the process of filing, but in the meantime, here’s a draft joint letter.

Thanks,

From: Christian Everdell CEverdell@CohenGresser.com Sent: Friday, October 29, 2021 7:55 PM

To:

STERNHEIM bcsternheim@mac.com; Laura Menninger Imenninger@hmflaw.com; Jeff Pagliuca jpagliuca@hmflaw.com

Cc:

Subject: (EXTERNAL] RE: Redactions: Government motion in limine

All —

I have confirmed that the government has incorporated all of the defense’s proposed redactions within the government’s proposed redactions. We do not have any more to add. For the record, we oppose the government redactions that are additional to the defense’s redactions.

We will now file the defense’s motions and exhibits, as redacted/sealed, and then wait for you to file the government’s response. It may take a little time to get them all filed, so bear with me.

Thanks,

Chris

Subject: RE: Redactions: Government motion in limine

All,

For filing purposes, attached are redacted versions of the defendant’s motions and exhibits, the government’s omnibus opposition, and the defendant’s omnibus reply. Below are our notes on which exhibits should be sealed. Please let us know if you would like to add any redactions or if you have any questions.

; BOBBI C

Defense Motions

Sealed

The following exhibits should be sealed

  • Exhibit A to Motion 4 (grand jury testimony)
  • Exhibit B to Motion 4 (grand jury testimony)
  • Exhibit 1 to Motion 7 (contact book)
  • Exhibit 2 to Motion 7 (deposition)
  • Exhibit A to Motion 8 (inventory)
  • Exhibit A to Motion 9 (photobook)
  • Exhibit to Motion 13 (various exhibits)

Redactions (attached)

  • Motion 1 and Exhibit 1 to Motion 1
  • Motion 2 and Exhibit A to Motion 2
  • Motion 3 and Exhibit 2 to Motion 3
  • Motion 4
  • Motion 7
  • Motion 8
  • Motion 9
  • Motion 10
  • Motion 13

No redactions

  • We are not seeking redactions to defense opening briefs for defense motions 5, 6, 11, and 12.
  • We are not seeking redactions to Exhibit 1 to Motion 3 (Government expert notice)

Government Opposition

  • We are not seeking to redact Government exhibits A and B (articles)

Defense Reply

Sealed

The following exhibits should be sealed

  • Exhibit A (tax documents)
  • Exhibit B (302)
  • Exhibit C (medical report)
  • Exhibit D (transcript)

No redactions

  • We are not seeking redactions to defense Exhibit E (English indictment)
From:
Sent: Friday, October 29, 2021 6:21 PM
To: Christian Everdell ceverdell@cohengresser.com•/ceverdell@cohengresser.com; BOBBI C
STERNHEIM bcsternheim@mac.com• Laura Menninger imenninger@hmflaw.com;
Jeff Pagliuca/imenninger@hmflaw.com/bcsternheim@mac.com
<jpagliticaphmflaw.com></jpagliticaphmflaw.com>
Cc:

Subject: RE: Redactions: Government motion in limine

Happy to jump on a call. We’re almost finished with the materials we’ll be sending you in a second wave, so why don’t we get the first wave filed, and we’ll send you the second set, and then we can get on the phone. Does that work?

From: Christian Everdell ceverdell@cohengressercom/ceverdell@cohengressercom
Sent: Friday, October 29, 2021 6:19 PM
To:
BOBBI C
•
STERNHEIM bcsternheim@mac.com• Laura Menninger <imenningejhmflaw.com>;</imenningejhmflaw.com>/bcsternheim@mac.com
Jeff Pagliuca
jpagliuca@hmflaw.com/jpagliuca@hmflaw.com
Cc:
Subject: [EXTERNAL] RE: Redactions: Government motion in limine
Got it. We are filing the response now.
I was thinking through the joint cover letter and I think there are a few more logistics we have to discuss. Can you jump
on a quick call?
From:
Sent: Friday, October 29, 2021 6:16 PM
; BOBBI C
To: Christian Everdell ceverdell@cohengresser.com•/ceverdell@cohengresser.com
Laura Menninger imenninger@hmflaw.com;
Jeff Pagliuca
STERNHEIM bcsternheim@mac.com;/bcsternheim@mac.com/imenninger@hmflaw.com
jpagliuca@hmflaw.com/jpagliuca@hmflaw.com
Cc:
Subject: RE: Redactions: Government motion in limine
Thanks for asking - yes, that’s correct.
From: Christian Everdell ceverdell@cohengressercom/ceverdell@cohengressercom
Sent: Friday, October 29, 2021 6:06 PM
To:
BOBBI C
STERNHEIM bcsternheim@mac.com;
Laura Menninger imenningej@hmflaw.com;
Jeff Pagliuca/imenningej@hmflaw.com/bcsternheim@mac.com
jpagliuca@hmflaw.com/jpagliuca@hmflaw.com
Cc:
Subject: [EXTERNAL] RE: Redactions: Government motion in limine
Just so I am clear on sequencing, you are now waiting for us to file the redacted version of our response brief, correct?
From:
Sent: Friday, October 29, 2021 5:49 PM
To: Christian Everdell ceverdell@cohengresser.com;
; BOBBI C/ceverdell@cohengresser.com
STERNHEIM bcsternheim@mac.com• Laura Menninger imenrung@hmflaw.com•
Jeff Pagliuca/imenrung@hmflaw.com/bcsternheim@mac.com
jpagliuca@hmflaw.com/jpagliuca@hmflaw.com
Cc:
Subject: RE: Redactions: Government motion in limine
Thanks, Chris. We’ll get this first group filed and then send you the next batch.
From: Christian Everdell ceverdell@cohengresser.com/ceverdell@cohengresser.com
Sent: Friday, October 29, 2021 5:42 PM
; BOBBI C STERNHEIM bcsternheim@mac.com;
To:
Laura/bcsternheim@mac.com
Menninger <imenninger
Jeff Pagliuca
hmflaw.com>;</imenninger
Cc:

Subject: [EXTERNAL] RE: Redactions: Government motion in limine

The redactions are consistent with what the government had proposed before. We do not have any redactions to add to these documents. But for the record, we object to all of the government’s proposed redactions.

Please send me the next batch when you have them ready.

Thanks,

Chris

From:
Sent: Friday, October 29, 2021 4:55 PM
To: Christian Everdell ceverdell@cohengresser.com• BOBBI C STERNHEIM bcsternheim@mac.com• Laura Menninger/bcsternheim@mac.com/ceverdell@cohengresser.com
Jeff Pagliuca <jpagliucaphmflaw.com>
<imenninger
hmflaw.com>;</imenninger
</jpagliucaphmflaw.com>
Cc:

Subject: Redactions: Government motion in limine

All,

Thanks for the call this afternoon, it was helpful to work through the mechanics of filing redactions this afternoon. As we discussed, we’re sending you versions of the following documents, with redactions applied: (1) the Government’s motion in limine, (2) the defendant’s opposition, and (3) the Government’s reply.

Please let us know if you would like us to add any redactions to these versions, and we’ll get them filed. With respect to Exhibits:

  • We are attaching a proposed redacted version of Government exhibit A.
  • Only defense exhibits E and G can be filed publicly without redactions.
  • All other defense exhibits to the defense opposition should be filed under seal.

Best,

Assistant United States Attorney United States Attorney’s Office Southern District of New York One St. Andrew’s Plaza New York, New York 10007

Tel:

Email chain among Maxwell trial counsel on redactions to motions in limine, Oct 2021

Emails and letters

Email chain between SDNY prosecutors and defense counsel coordinating redactions, sealing, and filing of motions in limine and exhibits ahead of trial.

DOJ Epstein Files, Data Set 8 · Oct. 29, 2021

| From: ' | | | |------------------------------------------------------------------------------------------------|----------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------| | To: Christian Everdell <ceverdell< td="" <th CohenGressencom&gt;, "</th <td </td </ceverdell< | CohenGressencom , " | | | | | , BOBBI C | | | | STERNHEIM <bcsternheim@mac.com , Laura Menninger <imenninger@hmflaw.com ,</imenninger@hmflaw.com </bcsternheim@mac.com | | | Jeff Pagliuca ipagliuca®hmf…