Email chain between Maxwell defense counsel and prosecutors on evidence review, 2021

EFTA00072432¶

1 St. Andrew’s Plaza New York, NY 10007¶

<rom: Laura Menninger lmenninger@hmflaw.com¶

Sent: Monday, March 15, 2021 3:01 PM¶

(USANYS)¶

Cc: Jeff Pagliuca jpagliuca@hmflaw.com; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com) ceverdell@cohengresser.com; ‘BOBBI C STERNHEIM’ bcsternheim@mac.com¶

Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes¶

Now that the FBI team is back, when do you expect to have answers to all of the questions posed? If I had an idea of when you would have answers, it could help me answer your question.¶

At a minimum, it would not seem to take too much time to know when someone can open the FBI vault and allow the attorneys to make an initial view of the evidence. Also, I understand the FBI did not prepare an inventory of their evidence when they seized it from NY and LSJ, so I don’t think we need to wait for them to now prepare an inventory before we start reviewing evidence.¶

Also, when do you believe you will have a response regarding the discovery I requested last Monday?¶

Thanks, Laura¶

Laura A. Menninger | Partner¶

Haddon, Morgan & Foreman, P.C.¶

150 E. 10th Avenue | Denver, CO 80203¶

+1 303 831 7364 (Office)¶

lmenninger@hmflaw.com¶

From:¶

Sent: Friday, March 12, 2021 11:44 AM¶

To: Laura Menninger lmenninger@hmflaw.com;¶

(USANYS) <¶

Cc: Jeff Pagliuca jpagliuca@hmflaw.com; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)¶

ceverdell@cohengresser.com; ‘BOBBI C STERNHEIM’ bcsternheim@mac.com¶

Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes¶

Counsel,¶

The FBI team on this case has been out of the office this week and will not be able to answer all of the questions you asked during our Wednesday call until they are back in the office next week. Please let me know if you would like to wait until all of those questions can be answered to schedule a day for your client to be brought to 500 Pearl Street to review the highly confidential images. My understanding is that the FBI is able to provide at least one laptop containing those highly confidential images in time for such a review to take place on Thursday 5/18, but I may not have the answers to all of your questions about those images before that date, and I do not know whether you will also be able to visit the evidence vault that same week.¶