Subject: RE: FW: DOJ Visit and Discovery

From: To Cc: Subject: RE: FW: DOJ Visit and Discovery Date: Thu, 10 Sep 2020 02:15:12 +0000 Inline-Images: image001.png; image002.jpg >, " (USANYS)" Got it, thanks very much Assistant United States Attorney Southern District of New York I St. Andrew's Plaza New York, NY 10007 From . Sent: Wednesday, September 9, 2020 9:43 AM To: ) Cc: Subject: RE: FW: Dal Visit and Discovery Good morning, (USANYS) No one here is aware of any Dal visitors for Ms. Maxwell today (or any other day either). Our regional director is visiting the institution today--my guess is that she overheard staff discussing this visit, and thought it pertained to her. I went to the mailroom today and there was nothing there, but I will have my paralegal check the warehouse and see if the hard drive has arrived. Sou, >» " " < > 9/8/2020 7:01 PM > » Thanks very much . Really appreciate the quick response. Please let us know if you learn of any planned visit from DOJ. Our office is are of any planned visit either. And apologies for the oversight, we must have forgotten to email you about the drive. Our paralegal sent a new drive out for Maxwell on Thursday, September 3rd. Attached are the two accompanying letters. Would you please look into its status for us? Thanks again, EFTA00097441 Assistant United States Attorney Southern District of New York I St. Andrew's Plaza New York. NY 10007 From Sent: Tuesday, September 8, 2020 6:44 PM To: Cc: Subject: Re: FW: Dal Visit and Discovery Good evening (USANYS) < I am unaware of any visit tomorrow by Dal representatives. I will raise this early tomorrow with staff and see if I can get any further details about this. When was the drive sent last week? We have received two drives to date - are you saying another was sent? I do not recall seeing any emails about a third set (if I missed it while out of the office, I apologize). Thanks, >»" „< > 9/8/2020 6:41 PM > » We just received the below email from Ghislaine Maxwell's attorney. Do you know what Dal representatives they are referring to? Regardless, per counsel's instruction below, please ensure that no DOJ representatives speak with Maxwell without her counsel present. Also, would you please check on the status of the drive our office sent out last week? I can be reached on my cellphone at and am happy to have a call if that would be useful. Thank you, Assistant United States Attorney Southern District of New York I St. Andrew's Plaza New York, NY 10007 From: Christian Everdell Sent: Tuesday, September 8, 2020 6:37 PM To: ) < (USANYS) c )* >; EFTA00097442 Cc: Mark S. Cohen >; Laura Menninger < ; Jeff Pagliuca Subject: Dal Visit and Discovery I hope you had a good Labor Day weekend. Our client has advised us that representatives from the Dal will be meeting with her in the MDC tomorrow. We are not clear who these representatives are or what they intend to meet with our client about. But it goes without saying that she is a represented party and that no representatives from DOJ should be speaking with her without her counsel present. We request that you notify the appropriate people at MDC about this as soon as possible. Also, our client has still not received the replacement hard drive you sent out on Thursday, September 3, at our request. As a result, it is now over two weeks past the August 21 deadline for completion of the initial tranche of discovery and Ms. Maxwell is still unable to review a substantial portion of the discovery produced to date. Ms. Maxwell cannot participate in her defense if she cannot review the discovery. Accordingly, we request that you expedite the delivery of the hard drive. Regards, Chris Christian Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 +1 212 707 7268 www.cohengresser.com New York I Seoul I Paris view bio Washington DC I London CONFIDENTIALITY NOTICE: The information contained in this e-mail may be confidential and/or privileged. This e-mail is intended to be reviewed initially by only the individual named above. If the reader of this e-mail is not the intended recipient or a representative of the intended recipient. you are hereby notified that any review. dissemination or copying of this e-mail or the information contained herein is prohibited. If you have received this e-mail in amt. please immediately notify the sender by telephone and permanently delete this e-mail. Thank you. PRIVACY: A complete copy of our privacy polky can be viewed:,! https://Www.cohengresser.com/privacL-policy EFTA00097443