VI LLAZOR
SMITH VI LLAZOR November 23, 2021 BY E-MAIL to The Honorable Alison J. Nathan United States District Judge Southern District of New York 40 Foley Square New York, New York 10007 Re: United States v. Maxwell. No. 20 Cr. 330 Smith Vittozor LLP 250 West 55th Street. 30th Floor New York. NY 10019 Dear Judge Nathan: We represent the independent administrator of the Epstein Victims' Compensation Program. We write regarding the Court's order, dated November 22, 2021, denying motion to quash Maxwell's subpoena to her and ordering production of the subpoenaed documents by November 24, 2021 at noon. ends to comply with the Court's order and produce responsive documents to the Court. However, given the volume of materials and the steps necessary to ensure that documents produced fall within the scope of the subpoena, it is not possible to produce all materials by noon tomorrow. We understand that the volume of potentially responsive materials is approximately 6,000 to 7,0
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SMITH VI LLAZOR November 23, 2021 BY E-MAIL to The Honorable Alison J. Nathan United States District Judge Southern District of New York 40 Foley Square New York, New York 10007 Re: United States v. Maxwell. No. 20 Cr. 330 Smith Vittozor LLP 250 West 55th Street. 30th Floor New York. NY 10019 Dear Judge Nathan: We represent the independent administrator of the Epstein Victims' Compensation Program. We write regarding the Court's order, dated November 22, 2021, denying motion to quash Maxwell's subpoena to her and ordering production of the subpoenaed documents by November 24, 2021 at noon. ends to comply with the Court's order and produce responsive documents to the Court. However, given the volume of materials and the steps necessary to ensure that documents produced fall within the scope of the subpoena, it is not possible to produce all materials by noon tomorrow. We understand that the volume of potentially responsive materials is approximately 6,000 to 7,0
Persons Referenced (3)
“...J. Smith Patrick J. Smith Smith Villazor LLP cc: Al.et , AUSA AUSA AUSA Christian R. Everdell, Esq., Jeffrey S. Pagliuca, Esq., Laura A. Menninger, Esq., Mark Stewart Cohen...”
JEFFREY S. PAGLIUCA“...Smith Villazor LLP cc: Al.et , AUSA AUSA AUSA Christian R. Everdell, Esq., Jeffrey S. Pagliuca, Esq., Laura A. Menninger, Esq., Mark Stewart Cohen, Esq., Bobbi C. Stemheim,...”
Patrick J. Smith“...re available should the Court have any questions. Respectfully submitted, /s/ Patrick J. Smith Patrick J. Smith Smith Villazor LLP cc: Al.et , AUSA AUSA AUSA Christian...”
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USDC SDNY
USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC 0: DATE FILED: 11/15/21 SMITH VILLAZOR November 15, 2021 BY E-MAIL to The Honorable Alison J. Nathan United States District Judge Southern District of New York 40 Foley Square New York, New York 10007 Re: United States v. Maxwell. No. 20 Cr. 330 Dear Judge Nathan: Smith Villazor LLF. New York, New York 10019 www.smithvillazor.com Patrick J. Smith may file a motion to quash the subpoena on or before Friday, November 19, 2021. The motion should not repeat arguments made in the Government's motion to quash, which is due on Thursday, November 18, 2021. The Defense shall respond to both motions on or before Monday, November 22, 2021. This memo endorsement is filed temporarily under seal to allow the parties to propose redactions. Any redactions to this letter and the Defendant's motion must be filed on the docket by November 21, 2021. SO ORDERED. We represent the independent admin'strator of the Epstein Victims
EFTA00038962
USDC SDNY
USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC 0: DATE FILED: 11/15/21 SMITH VILLAZOR November 15, 2021 BY E-MAIL to The Honorable Alison J. Nathan United States District Judge Southern District of New York New York, New York 10007 Re: United States v. Maxwell, No. 20 Cr. 330 Dear Judge Nathan: Smith Villazor LLF. New York, New York 10019 www.smithvillazor.com Patrick J. Smith may file a motion to quash the subpoena on or before Friday, November 19, 2021. The motion should not repeat arguments made in the Government's motion to quash, which is due on Thursday, November 18, 2021. The Defense shall respond to both motions on or before Monday, November 22, 2021. This memo endorsement is filed temporarily under seal to allow the parties to propose redactions. Any redactions to this letter and the Defendant's motion must be filed on the docket by November 21, 2021. SO ORDERED. We represen the independent admircstrator of the Epstein Victims' Compensation Pr
Subject: [EXTERNAL EMAIL] - FW: Activity in Case 1:20-cr-00330-VSB USA v. Maxwell Notice of
From: To: Subject: [EXTERNAL EMAIL] - FW: Activity in Case 1:20-cr-00330-VSB USA v. Maxwell Notice of Case Assignment/Reassignment Date: Fri, 01 Apr 2022 17:23:23 +0000 Importance: Normal Also FYI. This is all we know right now, but will keep you updated. From: NYSD_ECF_Pool@nysd.uscourts.gov <NYSD_ECF_Pool@nysd.uscourts.gov> Sent: Friday, April 1, 2022 12:52 PM To: CourtMail@nysd.uscourts.gov Subject: Activity in Case 1:20-cr-00330-VSB USA v. Maxwell Notice of Case Assignment/Reassignment This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e- mail because the mail box is unattended. ***NOTE TO PUBLIC ACCESS USERS••• Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid lat
VI LLAZOR
SMITH VI LLAZOR November 28, 2021 BY E-MAIL to The Honorable Alison J. Nathan United States District Judge Southern District of New York 40 Foley Square New York, New York 10007 Re: United States v. Maxwell. No. 20 Cr. 330 Smith Vittozor LLP 250 West 55th Street. 30th Floor New York. NY 10019 PATRICK J. SMITH Dear Judge Nathan: On behalf of non-party the independent administrator of the Epstein Victims' Compensation Program, and in accordance with the Court's memo-endorsement of our November 23, 2021 letter, we are making a third production to the Court of remaining documents responsive to defendant Maxwell's subpoena. We have posted the documents to a secure FTP site, which the Court, in its order dated November 27, 2021, indicated was a sufficient means of providing the documents. The credentials to the FTP site are the same as those we sent by email on November 26, 2021. We are producing in this production claim packets sent to attorneys for the four individ
From: Brian Bums
From: Brian Bums To: Cc: "ceverdel "bestemlielin (USANYS)" Subject: [EXTERNAL] RE: Subpoena fo Date: Sat, 20 Nov 2021 19:44:11 +0000 Attachments: 2021.11.15_-_ 1 - Letter from Patrick J. Smith to Judge_Nathan.pdf Jeff Pagliuca Inline-Images: image001.gif; image002.jpg Counsel - We are required to file our Nov. 15 letter to Judge Nathan on the public docket by tomorrow (copy attached for reference). We do not intend to apply any redactions. I assume that neither the government nor the defense proposes any redactions to this letter, but I'd appreciate confirmation before we file. Thanks, Brian T. Burns Smith Villazor LLP From: Sent: Wednesday, To: Jeff Pagliuca November 17, 2021 9:27 PM Brian Burns (USANYS) Subject: (EXTERNAL EMAIL] RE: Subpoena for Jordana Feldman >; Laura Menninger Thanks, Jeff. Brian, in light of Jeff's email, attached is the unredacted defense motion. Thanks. From: Jeff Pagliuca Sent: Wednesda November 17 2021 9:07 PM To: Brian Burns Cc:
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