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-Laura
Laura A. Henninger I Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue I Denver, CO 80203
+I 303 831 7364 (Office)
Imenninger(itilnflaw.com
From:
Sent: Wednesday, April 7, 2021 1:44 PM
To: Laura Menninger <Ienninger@hmflaw.com>•
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>• Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>. 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Hi Laura,
The Bronx warehouse is located at 2350 Lafayette Ave, Bronx, NY. There is plenty of street parking outside of the
building. Whatever day you wish to have the review conducted at the warehouse, an AUSA and an agent will meet the
attorney, investigator, and paralegal at the warehouse to escort them into the building to the evidence review room. The
AUSA will remain present at the warehouse to answer any questions that may arise.
The FBI has informed me that they can make the evidence available for review at the warehouse any day next week or the
week of April 19th. Please just let me know what day you prefer, and we will coordinate with the FBI to arrange for the
review.
Best,
Assistant United States Attorney
Southern District of New York
St. Andrew's Plaza
New York, NY 10007
From: Laura Menninger <Imenning @hmflaw.com>
Sent: Wednesday, April 7, 2021 3:30 PM
To:
>,
<->,
(USANYS) <
E>
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>• Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresseccom>. 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Thank you for the updated spreadsheets and the information regarding the timing of the review at 500 Pearl.
I believe we will be able to have an attorney, investigator and paralegal present at the Bronx warehouse to take photos of
the "excluded from transportation" items. Please let us know the particulars for that visit when you have a moment.
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Thank you,
Laura
Laura A. Menninger I Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue I Denver, CO 80203
+1 303 831 7364 (Office)
Imenninger@hmflaw.com
From:
Sent: Wednesday, April 7, 2021 10:06 AM
To: Laura Menninger <Imenninge
hmflaw.com>;
(USANYS)
Cc: Jeff Pagliuca <jpagliucaahmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com
<ceverdell@cohengresseccom>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Good morning,
Attached please find the revised spreadsheets, which reflect designations under the Protective Order for the three mini-
VHS tapes that I referenced below.
I learned this morning that the Marshals intend to bring Ms. Maxwell back to the MDC each review day at 4:30pm. So we
can plan for the review to take place at 500 Pearl Street from 9:30am to 4:30pm each day beginning on April 13th.
Best,
Assistant United States Attorney
Southern District of New York
St. Andrew's Plaza
New York, NY 10007
From:
Sent: Wednesday, April 7, 2021 12:09 AM
To: 'Laura Menninger' <lmenning @hmflaw.com>
<
=';
(USANYS)
Cc: 'Jeff Pagliuca' ipagliucaPhmflaw.com>• 'Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)'
<ceverdell@cohengresseccom>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Good evening,
Today, the Marshals confirmed that they will produce Ms. Maxwell to 500 Pearl Street on April 13, 2021 and every day
thereafter until the evidence review is complete. My understanding is that Ms. Maxwell should arrive to 500 Pearl Street
at approximately 9:30am each morning. So we are confirmed for evidence review in the proffer moms on the 5th floor of
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the 500 Pearl Street courthouse beginning at 9:30am on April 13th• I will plan to be present and to continue assisting with
logistics. If any questions or concerns arise, please feel free to call my cellphone at
To assist in preparing for this review, attached please find annotated versions of the three evidence spreadsheets I
previously emailed to you: (1) a spreadsheet of New York evidence; (2) a spreadsheet of Florida evidence; and (3) a more
detailed spreadsheet of the sub-items contained in the Florida evidence spreadsheet. A couple things to note:
• These spreadsheets now indicate the Protective Order designation, if any, for each item to be reviewed. As you will
see, there are three mini-VHS tapes that I need to double check before assigning a final designation. I expect to be
able to access a mini-VHS cassette player later this week, at which point I will be able to provide an updated