EFTA00105633 | | :--- | :---¶
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¶
EFTA00105634¶
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,¶