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efta-efta00211332DOJ Data Set 9Other

(USAFLS)" <1

From: (USAFLS)" <1 To: ' (USAFLS)" Subject: Re: Ghislaine Maxwell Date: Wed, 13 Apr 2016 14:55:49 +0000 Importance: Normal Inline-Images: image001.jpg (USAFLS)" If my edits make sense to both of you, I guess there's no reason we need to talk about them. On Apr 12, 2016, at 7:20 PM, (USAFLS) < > wrote: Here is my suggestion regarding a response, but we should discuss tomorrow. -Ed Dear Ms. Menninger: I am in receipt of your letter of April 6, 2016, where you have attempted to memorialize a telephone conversation in which you called me concerning Giuffre' Maxwell, Case No. 15-cv-07433-RWS (S.D.N.Y.), a civil case of which I have no knowledge beyond what you have represented. With respect to your understanding of our telephone conversation, let me make some clarifications. Due to pending litigation that was instituted against the U.S. Attorney's Office for the Southern District of Florida (the "Office"), the Office was recused by the Department of Justice from prospe

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DOJ Data Set 9
Reference
EFTA 00211332
Pages
3
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3
Integrity

Summary

From: (USAFLS)" <1 To: ' (USAFLS)" Subject: Re: Ghislaine Maxwell Date: Wed, 13 Apr 2016 14:55:49 +0000 Importance: Normal Inline-Images: image001.jpg (USAFLS)" If my edits make sense to both of you, I guess there's no reason we need to talk about them. On Apr 12, 2016, at 7:20 PM, (USAFLS) < > wrote: Here is my suggestion regarding a response, but we should discuss tomorrow. -Ed Dear Ms. Menninger: I am in receipt of your letter of April 6, 2016, where you have attempted to memorialize a telephone conversation in which you called me concerning Giuffre' Maxwell, Case No. 15-cv-07433-RWS (S.D.N.Y.), a civil case of which I have no knowledge beyond what you have represented. With respect to your understanding of our telephone conversation, let me make some clarifications. Due to pending litigation that was instituted against the U.S. Attorney's Office for the Southern District of Florida (the "Office"), the Office was recused by the Department of Justice from prospe

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From: (USAFLS)" <1 To: ' (USAFLS)" Subject: Re: Ghislaine Maxwell Date: Wed, 13 Apr 2016 14:55:49 +0000 Importance: Normal Inline-Images: image001.jpg (USAFLS)" If my edits make sense to both of you, I guess there's no reason we need to talk about them. On Apr 12, 2016, at 7:20 PM, (USAFLS) < > wrote: Here is my suggestion regarding a response, but we should discuss tomorrow. -Ed Dear Ms. Menninger: I am in receipt of your letter of April 6, 2016, where you have attempted to memorialize a telephone conversation in which you called me concerning Giuffre' Maxwell, Case No. 15-cv-07433-RWS (S.D.N.Y.), a civil case of which I have no knowledge beyond what you have represented. With respect to your understanding of our telephone conversation, let me make some clarifications. Due to pending litigation that was instituted against the U.S. Attorney's Office for the Southern District of Florida (the "Office"), the Office was recused by the Department of Justice from prospective responsibility for any criminal investigation or potential prosecution relating to Jeffrey Epstein's alleged sexual activities with minor females. As a result, the Office was also recused from any criminal investigation of Ms. Maxwell or anyone else relating to those allegations, and it thus has no pending investigations involving such matters. I did not understand your inquiry to involve any other criminal allegations, and my comments should not be understood to have addressed any other circumstances. (As a general matter, we do not comment on the existence or non- existence of criminal investigations for a variety of reasons.) Additionally, while I am personally unaware of any pending criminal investigation of Ms. Maxwell by any other authority, my lack of knowledge should not be construed as signifying either that there is or that there is not a pending criminal investigation of Ms. Maxwell. As for the Non-Prosecution Agreement involving Jeffrey Epstein, my only representation was that the name Ghislaine Maxwell does not appear in that document, as already reflected in public filings involving that document. If you understood my comments during our telephone conversation to have any broader or different meaning, I apologize for the misunderstanding. From: (USAFLS) Sent: ThursdlyL rll 07, 2016 12:34 PM To: (USAFLS); (USAFLS) Subject: FW: Ghislaine Maxwell EFTA00211332 Dear Ed and — This attorney for Ghislaine Maxwell called me and I picked up the call without knowing who it was. She asked me a series of questions which she claims that she wants to use in the civil suit between Ms. Maxwell and . I have attached her "confirming letter," which doesn't exactly capture what I said to her. I have no desire to be part of that suit and know nothing about it, but I also don't want her misrepresenting what I said. Any thoughts or advice? I thought about something like: Dear Ms. Menninger: I am in receipt of your letter of April 6, 2016, where you have attempted to memorialize our telephone conversation. The United States and the U.S. Attorney's Office are not parties to your suit and I am unaware of the representations that you discuss beyond what you have told me. To clarify, due to pending litigation, the U.S. Attorney's Office for the Southern District of Florida has been conflicted off of any investigations related to Jeffrey Epstein and Ghislaine Maxwell. Thus, this Office does not have a pending investigation of Ms. Maxwell. I am personally unaware of any pending criminal investigation of Ms. Maxwell by any other authority. The Non-Prosecution Agreement has been made public in other suits and the document does not mention Ms. Maxwell by name. I am running off to the OLEOs, but maybe we can discuss tomorrow? From: Laura Menninger Sent: WednescSSA06, 2016 4:11 PM To: , 1. (USAFLS) Subject: Ghislaine Maxwell Ms. Please see attached correspondence. Best regards, Laura <image001..jpg> Laura A. Menninger Haddon, Morgan and Foreman, E. 150 East 10th Avenue Denver, Colorado 80203 Main FX www.hmflaw.com I 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 EFTA00211333 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. EFTA00211334

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Related Documents (6)

Court UnsealedDepositionJul 31, 2020

[REDACTED - Survivor] Deposition May 2016

Case Document 1090-32 Filed 07/30/20 Page 1 of 89 EXHIBIT Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 2 of 89 GIUFFRE VS. MAXWELL Deposition [REDACTED - Survivor] 05/03/2016 _______________________________________________________________________ Agren Blando Court Reporting & Video, Inc. 216 16th Street, Suite 600 Denver Colorado, 80202 303-296-0017 Agren Blando Court Reporting & Video, Inc. Page 3 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 1 IN THE UNI

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DOJ Data Set 9OtherUnknown

COHEN & GRESSER LLP

GG COHEN & GRESSER LLP Christian R. Evercle11 +1 (212) 957-7600 ccvcrdclIgathcngresscr.com October 13, 2020 BY EMAIL. , Esq. Esq. Esq. United States Attorney's Office Southern District of New York 1 St. Andrew's Plaza New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear 000 Thud Avenue New Yoek. NY 10022 +1 212 957 7600 phone owswoohensresser corn We write on behalf of our client, Ghislaine Maxwell, to set forth requests for discovery and Brady material. Based on our review of the government's productions of August 5, 2019, August 13, 2019, and August 21, 2020, we make the following requests for discovery, inspection, and copying, in accordance with the guarantees of the Fourth, Fifth, and Sixth Amendments, Rule 16 of the Federal Rules of Criminal Procedure, the Federal Rules of Evidence, and such other laws and rules as may be applicable. We are still reviewing these productions, as well as the government's most recent production of

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DOJ Data Set 9OtherUnknown

U.S. Department of Justice

U.S. Department of Justice United States Attorney Southern District of New York The Silvio I. Motto Building One Saint Andrew's Plaza New York. New York 10007 October 2, 2020 BY ELECTRONIC MAIL Christian Everdell, Esq. Mark Cohen, Esq. Cohen & Gresser LLP New York, N Laura Menninger, Esq. Jeffrey Pagliuca, Esq. Haddon. Mor an and Foreman, P.C. Denver, CO Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Counsel: In recognition of the Government's ongoing discovery obligations, today we are producing copies of the materials listed in the below index, which materials are stamped with control numbers SDNY GM 000174967 through SDNY_GM_ 00328863. The password for the drive is The materials are available for pickup at the U.S. Attorney's Office in Manhattan. Please note that both this letter and the enclosed materials are governed by the July 31, 2020 Protective Order in this case.' This letter is itself designated as "confidential," because it includes i

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DOJ Data Set 9OtherUnknown

U.S. Department of Justice

U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 October 28, 2021 BY ELECTRONIC MAIL Christian Everdell, Esq. Mark Cohen, Esq. Cohen & Gresser LLP 800 Third Avenue New York, NY 10022 Laura Menninger, Esq. Jeffrey Pagliuca, Esq. Haddon, Morgan and Foreman, P.C. 150 East Tenth Avenue Denver, CO 80203 Bobbi Stemheim, Esq. Law Offices of Bobbi C. Stemheim 33 West 19th Street-4th Fl. New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Counsel: Today we are producing the materials listed in the below index. These materials are stamped with control numbers SDNY_GM_02765768 through SDNY_GM_02767073. Please note that both this letter and the enclosed materials are governed by the July 31, 2020 Protective Order in this case. This letter is itself designated as "confidential," because it includes information regarding records design

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DOJ Data Set 8CorrespondenceUnknown

EFTA00020978

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DOJ Data Set 8CorrespondenceUnknown

EFTA00018663

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