Skip to main content
Skip to content
Case File
efta-efta00014661DOJ Data Set 8Correspondence

EFTA00014661

Date
Unknown
Source
DOJ Data Set 8
Reference
efta-efta00014661
Pages
0
Persons
0
Integrity
Loading PDF viewer...

Summary

Ask AI About This Document

0Share
PostReddit

Extracted Text (OCR)

EFTA Disclosure
Text extracted via OCR from the original document. May contain errors from the scanning process.
From: ' To: Laura lvlennin er <ImenningerOiNnflav,%com (USANYS)" Cc: Jeff Pagliuca <jpagliucaghmflaw.com>, mceverdellgcohengresser.coni" <ceverdellgcohengresser.com>, "'Bobbi Sternheim (bestemheimgmac.com)"' <bcstemheim@2mac.com> Subject: RE: Conferral Regarding Possible Violation of Local Criminal Rule 23.1 Date: Wed, 12 May 2021 03:03:03 +0000 Inline-Images: image001.jpg Counsel, To our knowledge, Spencer Kuvin does not represent any of the witnesses the Government expects to call at trial in this case. Because this individual does not represent any witnesses in this case, we do not see a need to raise this issue with the Court. We agree that compliance with Local Rule 23.1 is important. To that end, we note that David Markus, an attorney who has filed a notice of appearance in the Second Circuit on behalf of Ms. Maxwell, and who was present for the arraignment before Judge Nathan last month, has also made public statements to the press regarding this case, which run the risk of violating the rule. See, e.g., https://nypost.com/2021/05/05/ghislaine-maxwell-on-enhanced-security-schedule-lockup- fecIst Our hope is that by alerting you to this concern now, there will not be a need in the future to raise the issue with the Court. Best, From: Laura Menninger <Imenninger@hmflaw.com> Sent: Friday, May 7, 2021 5:18 PM To: >; (USANYS) Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; iceverdell@cohengresser.com' <ceverdell@cohengresser.com>; 'Bobbi Sternheim (bcsternheim@mac.com)' <bcsternheim@mac.com> Subject: Conferral Regarding Possible Violation of Local Criminal Rule 23.1 Counsel — The linked article by the Sun dated yesterday contains a number of statements which, if made by a lawyer associated with a witness in this case, appear to violate Local Criminal Rule 23.1. See also Dkt. No. 28 (expectation of strict compliance with Rule 23.1 by "counsel for all involved parties"). The rule applies by its terms to any "lawyer participating in or associated with the investigation (including ... lawyers for targets, subjects, and witnesses in the investigation...):' https://www.thesun.co.uk/news/14875477/ghislaine-maxwell-plea-deal-same-fate-as-epstein/ I am writing to confer with you prior to bringing this to the Court's attention. Please let me know if you believe Mr. Spencer Kuvin represents any witness in this case. Given the urgency of this situation, I would appreciate a response by close of business Monday. EFTA00014661 Thanks, Laura Laura A. Menninger Haddon, Morgan and Foreman, P.C. 150 East 10th Avenue Denver, Colorado 80203 Imenninger@hmflaw.com www.hmflaw.com CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages attached to it may contain information that is confidential or legally privileged. If you are not the intended recipient, or a person responsible for delivering it to the intended recipient, you are hereby notified that you must not read this transmission and that any disclosure, copying, printing, distribution or use of any of the information contained in or attached to this transmission is STRICTLY PROHIBITED. If you have received this transmission in error, please notify the sender by telephone or return e-mail and delete the original transmission and its attachments without reading or saving it in any manner. Thank you. EFTA00014662

Technical Artifacts (13)

View in Artifacts Browser

Email addresses, URLs, phone numbers, and other technical indicators extracted from this document.

Domainbestemheimgmac.com
Domainceverdellgcohengresser.com
Domainjpagliucaghmflaw.com
Domainwww.hmflaw.com
Emailbcstemheim@2mac.com
Emailbcsternheim@mac.com
Emailceverdell@cohengresser.com
Emailiceverdell@cohengresser.com
Emailimenninger@hmflaw.com
Emailjpagliuca@hmflaw.com
Phone14875477
URLhttps://nypost.com/2021/05/05/ghislaine-maxwell-on-enhanced-security-schedule-lockup
URLhttps://www.thesun.co.uk/news/14875477/ghislaine-maxwell-plea-deal-same-fate-as-epstein

Related Documents (6)

DOJ Data Set 9OtherUnknown

From: '

From: ' y. „cl [Contractor]" (USANYSCo ntractor " (USANYS) [Contractor To: ' Cc: ' (USANYS ) [Contractorr <W " ) (USANYS)" Subject: RE: Discovery Issues Date: Wed, 12 May 2021 13:54:21 +0000 Great, thanks very much. Let's say 11am? From: (USANYS) [Contractor] < Sent: Wednesday, May 12, 2021 9:43 AM To: (USANYS) [Contractor] Cc: Subject: Re: Discovery Issues As am I. On May 12, 2021, at 9:36 AM, From: Sent: Tuesday, May 11, 2021 10:41 PM To: (USANYS) [Contractor] < (USANYS) [Contractor] (USANYS) [Contractor] < M> Cc: (USANYS)<a Subject: FW: Discovery Issues and I are both available anytime today. (USANYS) [Contractor) (USANYS) (USANYS) [Contractor] < wrote: Hi team, Maxwell's attorneys have asked for the below-listed information from the SUPP production that went out on November 9, 2021. Is there a time tomorrow when we can have a call to discuss, please? Thanks, From: Laura Menninger Sent: Friday, May 7, 20214:53 PM To: >; Christian Everdell

7p
DOJ Data Set 8CorrespondenceUnknown

EFTA00032783

0p
DOJ Data Set 9OtherUnknown

To: Laura Mennin. er •

From: To: Laura Mennin. er • Jeff Pagliuca Cc: '1 >, aff,IJSANrai > ) 4° Subject: RE: [EXTERNAL] Proposed Jury Questionnaires Date: Wed, 13 Oct 2021 01:35:59 +0000 Attachments: 2021.10.12 Joint_proposed_Maxwell_Trial_Length_Letters _v3.pdf Thanks, Laura. This works for us — we've just added a couple sentences noting our production yesterday to our section. I'll plan to file this at 10. Shanks From: Laura Menninger Sent: Tuesday, October 12, 2021 7:58 PM To: Pagliuca ‹ > Cc: ) (USANYS) Subject: RE: [EXTERNAL] Proposed Jury Questionnaires < >.H > ; Jeff Thanks. Here is our position for the joint letter. I'll leave to your discretion whether you want to keep the final paragraph of your position given it is redundant of the joint position. Also, I'm not clear why our report to you would be spelled out in your position rather than ours, so I moved it. Thanks — Laura From: Sent: Tuesday, October 12, 2021 5:46 PM To: Laura Menninger Cc: (USANYS) •t > Subject

8p
DOJ Data Set 9OtherUnknown

To: Laura Mennin er tennin e

From: To: Laura Mennin er tennin e mflaw.com>, " " • (USANYS)" Cc: Jeff Pagliuca ipagliuca@hmflaw.com>, "Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)" <ceverdell@cohengresser.com>, 'BOBBI C STERNHEIM' <bcstemheim@mac.com> Subject: RE: US v. Maxwell - 20 Cr. 330 (MN) - Request to view evidence, highly confidential materials, scenes Date: Sat, 27 Mar 2021 22:38:06 +0000 Inline-Images: image001.jpg Counsel, Thank you for your email. Below please find our response. If this is acceptable to you, then we will proceed with arranging the logistics of having your client produced to 500 Pearl the week of April 12th and the week April 19th. We will also arrange for the FBI to transport evidence to 500 Pearl for review the week of April 12rh. Physical Evidence • It is not reasonable or feasible to insist that the FBI bring all physical evidence to 500 Pearl Street. That said, we are certainly willing to work with you to ensure that your client can revi

10p
DOJ Data Set 9OtherUnknown

(USANYS) [Contractor]"

From: To: ' Cc: " (USANYS) [Contractor]" s-M > (USANYS)" (USANYS) [Contractor)" Subject: RE: US v. Maxwell - [conferral re photo and other discovery deficiencies] Date: Wed, 11 Aug 2021 21:33:23 +0000 Attachments: Maxwell_problem_filess images_Not_Exported.xlsx Hi again, Good news, was able to run searches for those last 200 files way more quickly than anticipated. Let me know what you think of the attached spreadsheet. The Bates number column indicates a Bates number Maxwell/her counsel identified as one she had an "images not exported" issue; the "Export File" column indicates what Relativity production export it was from; and the "Relativity Search Result" column indicates what the possible issue is with the Bates number identified. Descriptions of each type of entry in the spreadsheet are below. Let me know if you have any questions. Thanks, CORRUPTED DOC W/ EXTRACTED TEXT - This indicates that the original document was corrupt but we were able to supply extracted

9p
DOJ Data Set 8CorrespondenceUnknown

EFTA00028646

0p

Forum Discussions

This document was digitized, indexed, and cross-referenced with 1,400+ persons in the Epstein files. 100% free, ad-free, and independent.

Annotations powered by Hypothesis. Select any text on this page to annotate or highlight it.