FYI. Apparently they think third time’s the charm.¶
| From: Sent: Tuesday, February 23, 2021 2:54 PM | |
|---|---|
| <la To: (USANYS) (USANYS) (USANYS) < Cc: Subject: FW: U.S. v. Maxwell 20 Cr. 330 (AJN)</la | |
| FYI | |
| From: BOBBI C STERNHEIM Sent: Tuesday, February 23, 2021 2:44 PM | |
| <->; ) To: `c | |
| (USANYS) ; Laura Menninger < Cc: Christian Everdell | >; Jeff Pagliuca |
| Subject: U.S. v. Maxwell 20 Cr. 330 (AJN) | |
| Good afternoon | |
| Attached is a courtesy copy of today’s ECF filing. | |
| Bobbi | |
| BOBBI C. STERNHEIM, ESQ. Law Offices of Robbi C. Stcrnheim | |
This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim¶
that may be confidential and/or privileged.¶
If you are not the intended recipient, you may not read, copy, distribute, or use this information. If you have received this transmission in error, please notify the sender immediately by reply e-mail and then delete this message. Thank you.¶
Thanks—I think it would help to even more expressly note that the document is not comprehensive (for example, this spreadsheet doesn’t list the yearbooks, so it sounds like it’s missing more recent evidence). Proposed addition below.¶
To my knowledge, that is the only excel spreadsheet in our possession that indexes physical evidence related to this case, but this is not a comprehensive document. The discovery productions also included search warrant returns listing the physical items seized by the FBI’s New York Office during the 2019 searches of Jeffrey Epstein’s residences in New York and the U.S Virgin Islands, but they are not contained in a spreadsheet.¶
As a courtesy, I have asked the FBI whether it would be possible to provide us with a similar excel index reflecting the physical evidence seized by the FBI’s New York Office, though it may take some time to complete such an index.¶
Best,¶
| From: | |||
|---|---|---|---|
| Sent: Tuesday, March 9, 2021 3:57 PM | |||
| To:I | ) | (USANYS) | |
Subject: FW: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes¶
Proposed response below. Good with you?¶
To my knowledge, that is the only excel spreadsheet in our possession that indexes physical evidence related to this case. The discovery productions also included search warrant returns listing the physical items seized by the FBI’s New York Office during the 2019 searches of Jeffrey Epstein’s residences in New York and the U.S Virgin Islands, but they are not contained in a spreadsheet.¶
As a courtesy, I have asked the FBI whether it would be possible to provide us with a similar excel index reflecting the physical evidence seized by the FBI’s New York Office, though it may take some time to complete such an index.¶
Best,¶
| From: Laura Menninger <imenning hmflaw.com></imenning |
|---|
| Sent: Tuesday, March 9, 2021 3:44 PM |
| <->, To: ) |
| .> (USANYS} |
| Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com) Cc: Jeff Pagliuca <jpagliucaphmflaw.com>•</jpagliucaphmflaw.com> |
ceverdell@cohengresser.com; %CHIEN C STERNHEIM’ bcsternheim@mac.com Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes¶
Thank you. Is that the only index of physical evidence available?¶
Laura A. Menninger I Partner Haddon, Morgan & Foreman, P.C. 150 E. 10th Avenue I Denver, CO 80203 +1 303 831 7364 (Office) Imenninger@hmflaw.com¶
From: Sent: Tuesday, March 9, 2021 1:38 PM To: Laura Menninger ImenningerL@hmflaw.com (USANYS) Cc: Jeff Pagliuca <jpagliucaahmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com) ceverdell@cohengresser.com•13O881C STERNHEIM’ bcsternheim@mac.com¶
Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes¶
Counsel,¶
In advance of our call tomorrow, I wanted to send a copy of the attached index of physical items in FBI custody from the FBI-Miami office, which we previously produced to you as part of our August 21, 2020 discovery production. Also included in that August 21, 2020 production were scans of numerous items listed on the index. Those scans can be found within Bates range SDNY_GM_00172218-SDNY_GM_00173007. It may be useful to reference some of those items during our conversation tomorrow, so I wanted to make sure you were aware of them.¶
Best,¶
Assistant United States Attorney Southern District of New York 1 St. Andrew’s Plaza New York, NY 10007¶
From: Sent: Tuesday, March 9, 2021 2:03 PM To: ‘Laura Menninger’ Imenninger@hmflaw.com• al›; (USANYS) Cc: Jeff Pagliuca <jpagliucaahmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdellPcohengresser.com) ceverdell@cohengresser.com• ‘BONI C STERNHEIM’ bcsternheim@mac.com Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes¶
Yes, that works for us, thank you very much. We can use the below dial-in:¶
Dial-in: Code:¶
| From: Laura Menninger imenninger@hmflaw.com Sent: Tuesday, March 9, 2021 11:19 AM/imenninger@hmflaw.com |
|---|
| ) sca; To: ; ) ) 4. > (USANYS)< Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com) Cc: Jeff Pagliuca <jpagliucaphmflaw.com>. ceverdell@cohengressercom. ‘BOBBI C STERNHEIM’ bcsternheim@mac.com Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes/bcsternheim@mac.com/ceverdell@cohengressercom</jpagliucaphmflaw.com> |
| Good morning, |
| We are free at 1:30 p.m. ET / 11:30 a.m. MST tomorrow. Would that work? We are generally free thereafter, so please suggest another later time if not. |
| Thank you, Laura |
| Laura A. Henninger I Partner Haddon, Morgan & Foreman, P.C. 150 E. 10th Avenue I Denver, CO 80203 +I 303 831 7364 (Office) Imenninger(Ounflaw.com |
| From: Sent: Tuesday, March 9, 2021 8:36 AM |
(USANYS) Cc: Jeff Pagliuca jpagliuca@hmflaw.com. Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com) ceverdell@cohengresseccom>. ‘BOBBI C STERNHEIM’ bcsternheim@mac.com¶
Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes¶
Good morning,¶
It would be helpful to have a call to discuss the requests contained in this letter. Are there times tomorrow when you would be available to speak, please?¶
Thank you,¶
Assistant United States Attorney Southern District of New York 1 St. Andrew’s Plaza New York, NY 10007¶
To: Laura Menninger <ImenningeSimflaw.com>.¶
To: > -)sc l>%¶
(USANYS) .> Cc: Jeff Pagliuca ipagliucaahmflaw.com>. Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com) ceverdell@cohengresseccom>. ‘BOBBI C STERNHEIM’ bcsternheim@mac.com Subject: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes¶
Counsel —¶
Please see attached correspondence.¶
-Laura¶
Laura A. Menninger Haddon, Morgan and Foreman, P.C. 150 East 10th Avenue Denver, Colorado 80203 Main 303.831.7364 FX 303.832.2628 Imenninger@hmflaw.com www.hmflaw.com¶
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