From: Laura Menninger lmenninger@hmflaw.com¶
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¶
Date: Mon, 15 Mar 2021 19:00:36 +0000¶
Inline-Images: image001.jpg¶
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)¶
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.¶
| EFTA00077560 | | :--- | :--- |¶
This is a simple Markdown document with no headings or paragraphs. It contains a single line of text.¶
Please let me know how you would like to proceed. I will reach back out once I have answers to your questions.¶
Thank you,¶
Assistant United States Attorney Southern District of New York¶
1 St. Andrew’s Plaza¶
New York, NY 10007¶
From:¶
Sent: Tuesday, March 9, 2021 4:56 PM¶
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¶
That is the only excel spreadsheet indexing physical evidence that we have produced in discovery. That spreadsheet does not include every physical item currently in the FBI’s custody related to this case. For example, the August 20, 2020 discovery production 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 (see Bates range SDNY_GM_00166007-SDNY_GM_00166043), 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 compile such an index.¶
Best,¶
Assistant United States Attorney¶
Southern District of New York¶
1 St. Andrew’s Plaza¶
New York, NY 10007¶
From: Laura Menninger lmeninger@hmflaw.com¶
Sent: Tuesday, March 9, 2021 3:44 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¶
| EFTA00077561 | | :--- | :--- |¶
This is a simple Markdown document with no headings or paragraphs. It contains a single line of text.¶
Thank you. Is that the only index of physical evidence available?¶
Laura A. Menninger | Partner¶
Haddon, Morgan & Foreman, P.C.¶
150 E. 10th Avenue | Denver, CO 80203¶
+1 303 831 7364 (Office)¶
From:¶
Sent: Tuesday, March 9, 2021 1:38 PM¶
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,¶
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’ <\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¶
Yes, that works for us, thank you very much. We can use the below dial-in:¶
Best,¶