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From•
To:
Subject:
Date: Thu, 08 Apr 2021 18:20:05 +0000
Embedded: Re:_Follow-up.msg
Assistant United States Attorney
Southern District of New York
New York, NY 10007
EFTA00015752
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From: Christian Everdell <CEverdell®ColtenGresser.com>
To: "1
, 'Laura IvIennintter
<Imennin er hmflaw.com>, '
(USANYS)"
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>, 'BOBBI C STERNHEIM'
<bcstemheimgmac.com>
Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential
materials, scenes
Date: Thu, 08 Apr 2021 21:22:13 +0000
Inline-Images: image001.jpg
Thanks,
11am is fine. I don't think we will need more time. If for some reason we need to go back later in the
week, we can arrange for another trip to finish up.
From:
[mailto
Sent: Thursday, April 08, 2021 5:19 PM
To: Christian Everdell; 'Laura Menninger';
(USANYS)
Cc: Jeff Pagliuca; 'BOBBI C STERNHEIM'
Subject: RE: US v. Maxwell - 20 Cr. 330 (MN) - Request to view evidence, highly confidential materials, scenes
Chris,
I am going to be tied up for a bit the morning on the 12th. Would it work on your end to meet at the warehouse at 11am,
please? The warehouse will be open until 4:30pm, though I'm told I can request additional time in advance if you think
the review will take more than 5'A hours.
Also, I am working on gathering information in response to Laura's email and expect to be able to respond to it later this
evening.
Thank you,
Assistant United States Attorney
Southern District of New York
I St. Andrew's Plaza
New York, NY 10007
From: Christian Everdell <CEverdell@CohenGressercom>
Sent: Thursday, April 8, 2021 5:06 PM
To: 'Laura Menninger' <Imenninger@hmflaw.com>;
(USANYS) sc
>
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US v. Maxwell - 20 Cr. 330 (MN) - Request to view evidence, highly confidential materials, scenes
EFTA00015753
--- PAGE 2 ---
I plan to arrive at the warehouse on April 12 with an investigator and a paralegal at around 9:30am. Does that work?
Thanks,
Chris
From: Laura Menninger [mailto:Imenningerehmflavir.com]
Sent: Wednesday, April 07, 2021 4:23 PM
To:
)';
);
(USANYS)
Cc: Jeff Pagliuca; Christian Everdell; 'BOBBI C STERNHEIMI
Subject: RE: US v. Maxwell - 20 Cr. 330 (MN) - Request to view evidence, highly confidential materials, scenes
My apologies, I meant to include in my previous email that we could have the Bronx view on Monday April 12. Thank you
for the logistics.
Regarding the spreadsheets you provided, I have several issues.
First, there are a couple of items that you have noted for the Bronx Warehouse but will in fact need to be brought to 500
Pearl for review because you labeled them as "Highly Confidential" and not "bulky." These appear to include:
NY Evidence List
• Items 16127-130 (4 boxes).
• Item 1B13 (1 box)
Florida Evidence List
• Item 1, Subitem 26 — one large framed photo from Master Bedroom.
Second, with regard to the "Bulky" photos (Florida Items 1, Subitems 8, 15a, 15b and 15c), are we permitted to
photograph those or not? If not, we will need them transported to 500 Pearl.
Third, Florida Item 8, Subitem 8, says it is Sixteen DVD-R Discs from PBSO but you do not indicate that we can review
those. Why? We need to address with the Court promptly any issues related to our request to view all evidence.
Fourth, Electronic surveillance — Your email yesterday stated that these were all "electronic files" with no corresponding
physical item. However, for several, the chart indicates "Blu-Ray Disks;" is there a reason we cannot inspect these?
Another Florida item is listed as "one original recording of an interview dated 4/24/07"; I am suspicious that "one original
recording of an interview" is not truly only an "electronic" file? I was practicing law in 2007 and do not recall "electronic
files" being the standard then. Can you please confirm? I know that Chris has written separately about the many files for
which the metadata has apparently been stripped, so we will have to address purely electronic information at another
date.
Shredded Paper — Yes, we need to review that as well.
"Missing from Assigned Box" items — can you please provide more of an explanation for all "missing items"?
I will let you know any other issues as I see them. However, now that we have made travel plans in reliance on your
agreement to produce all evidence items, I am hoping that you can promptly answer these questions so that we can
resolve any of them as needed this week.
Thank you,
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