Subject: RE: US v. Maxwell, 20 Cr. 330 (AJN) - non-testifying witness production¶
Date: Wed, 28 Jul 2021 13:04:41 +0000¶
Attachments: 2021.07.28_Maxwell_Discovery_Letter.docx¶
The production is all set to go out. I’ve stamped the PBSD Education Records and Epstein Photo Book confidential with the same stamp as was used for the most recent NTW batch. Attached is a drafted cover letter to go along with these materials.¶
Sent: Tuesday, July 27, 2021 7:39 PM¶
Subject: RE: US v. Maxwell, 20 Cr. 330 (AJN) - non-testifying witness production¶
Thanks very much,¶
Would it be possible to please prep everything in the discovery folder here:¶
\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-2018R01618\Discovery\GM\27 Eighteenth Production (2021-07-xx)¶
We are designating the PBSD Education Records and the Epstein Photo Book confidential, so please use the new stamp we used for the most recent NTW batch for those materials. The rest do not need a designation.¶
If that can get done quickly, I’d be inclined to include that production on the drives for tomorrow.¶
Subject: RE: US v. Maxwell, 20 Cr. 330 (AJN) - non-testifying witness production¶
The drive for defense has been loaded. The drive for Maxwell has not yet been loaded.¶
Subject: RE: US v. Maxwell, 20 Cr. 330 (AJN) - non-testifying witness production¶
EFTA00104573¶
Hey,¶
I have the drives and work on getting them loaded. Are we including anything else on the 1TB drive for Maxwell?¶
Thanks,¶
Subject: Fwd: US v. Maxwell, 20 Cr. 330 (AJN) - non-testifying witness production¶
Hi all,¶
Would one of you please be able to track down these drives for the Maxwell NTW production? They were apparently addressed to¶
Thanks!¶
Begin forwarded message:¶
From: Christian Everdell CEverdell@cohengresser.com¶
Date: July 27, 2021 at 9:25:23 AM EDT¶
To: Ӧ
| Cc:"Bobbi Sternheim(bcsternheim@mac.com)" | <bcsternheim@mac.com>, Jeff Pagliuca<jpagliuca@hmflaw.com>, |
| "Mark S. Cohen"<mcohen@cohengresser.com>, Laura Menninger<lmenninger@hmflaw.com>, | " |
Subject: Re: US v. Maxwell, 20 Cr. 330 (AJN) - non-testifying witness production¶
It was addressed to . Let me know if you can’t find them.¶
Sent from my iPhone¶
On Jul 27, 2021, at 9:10 AM,¶
Thanks very much, Chris. Who were the drives addressed to? I have not received them yet, so I’m wondering whether they might have gone to someone else’s office.¶
From: Christian Everdell <CEverdell@CohenGresser.com>¶
Sent: Sunday, July 25, 2021 11:22 PM¶
; Bobbi Sternheim (bcsternheim@mac.com)
¶
bcsternheim@mac.com; Jeff Pagliuca jpagliuca@hmflaw.com; Mark S. Cohen mcohen@CohenGresser.com;¶
Laura Menninger lmenninger@hmflaw.com¶