EFTA00030035.pdf

From: ' To: Christian Everdell <CEverdell CohenGressencom>, 'Laura Menninger' <Imennin er hmtlaw.com>, ' (USANYS)" Cc: Jeff Paglitica <jpaglincaghmflaw.com>, 'BOBS! 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 21:19:26 +0000 Inline-Images: image001.jpg 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 1 St. Andrew's Plaza New York, NY 10007 From: Christian Everdell <CEverdell@CohenGresseccom> Sent: Thursday, April 8, 2021 5:06 PM To: 'Laura Menninger' <Imenninger@hmflaw.com>; < (USANYS) st> Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com> Subject: RE: US v. Maxwell - 20 Cr. 330 (AM) - Request to view evidence, highly confidential materials, scenes 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 EFTA00030035 From: Laura Menninger [mailto:Imenninger©hmflaw.com] Sent: Wednesda Aril 07 2021 4:23 PM To: y; ); (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, -Laura Laura A. Menninger I Partner Haddon, Morgan & Foreman, P.C. 150 E. 10th Avenue I Denver, CO 80203 +I 303 831 7364 (Office) Imenninger(unflaw.com EFTA00030036 From: Sent: Wednesday, April 7, 2021 1:44 PM To: Laura Menninger <Imenninger@hmflaw.com>• (USANYS) Cc: Jeff Pagliuca <jpagliucaCiilhmflaw.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 <ImenningerPhmflaw.com> Sent: Wednesday, April 7, 2021 3:30 PM To: ) ca; (USANYS) ‹> Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>• Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com) <ceverdell@cohengressercom>. '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. Thank you, 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(idunflaw.com EFTA00030037 From: Sent: Wednesday, April 7, 2021 10:06 AM To: Laura Menninger <ImenningerPhmflaw.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 < 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 I St. Andrew's Plaza New York, NY 10007 From: Sent: Wednesday, April 7, 2021 12:09 AM To: 'Laura Menninger' <IrnenningerPhmflaw.com>; (USANYS) Cc: 'Jeff Pagliuca' <jpagliucaPhmflaw.com>. 'Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.con)' <ceverdell@cohengressercom>. '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 rooms on the 5th floor of t