EFTA00087964.pdf

Thanks very muchill. From: ' )" U To Cc: a' )" < >, " (USANYS)" Subject: RE: DOJ Visit and Discovery Date: Thu, 10 Sep 2020 15:55:22 +0000 Got it, will do. Thanks very much. Fro Sent: Thursday, September 10, 202011:42 AM To: Cc: Subject: RE: DOJ Visit and Discovery (USANYS) < She should have it. If he tells you anything differently today or tomorrow, let me know. Fro SenrittMirbera7 AM To: Cc: Subject: Re: DOJ Visit and Discovery > 9/10/202010:36 AM > » (USANYS) < It was delivered around 3 pm, which I believe was after her call with counsel. I will double check with my paralegal though. Thanks, >>>„ „< Hi Maxwell's attorney just emailed me saying that his client still has not received this drive. Would you please confirm for us tomorrow that she has this drive? Thanks very much, On Sep 9, 2020, at 8:17 PM, > 9/10/2020 12:01 AM >> > <!--[if mso 9]--> <![endif]--> Thank you so much Really appreciate you looking into that. Best, Assistant United States Attorney Southern District of New York wrote: EFTA00087964 l St. Andrew's Plaza New York, NY 10007 From: Holly Pratesi Sent: Wednesday, September 9, 2020 4:45 PM To: Cc: °: >; Subject: RE: FW: DOJ Visit and Discovery Drive was delivered today. Bes (USANYS)<I > >» " " < > 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 Dal. Our office is not aware 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, Assistant United States Attorney Southern District of New York l St. Andrew's Plaza New York, NY 10007 From: Holly Pratesi Sent: Tuesday, September 8, 2020 6:44 PM To: Cc: ) (USANYS) c )a Subject: Re: FW: Dal Visit and Discovery Good evening I am unaware of any visit tomorrow by DOJ 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 DOJ 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 EFTA00087965 New York, NY 10007 From: Christian Everdell Sent: Tuesday, September 8, 2020 6:37 PM To: (USANYS) Cc: Mark S. Cohen I s . • c->; Laura Menninger c ; Jeff Pagliuca ope you a a goo a or ay 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 <image001.png> 800 Third Avenue New York, NY 10022 I view bio www.cohengresser.com New York I Seoul I Paris I Washington DC I London <image002.jpg> CONFIDENTIALITY NOTICE: The information contained in this e-mail may be confidential and/or privileged. This e-mail is intended fo 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 error. please immediately notify the sender by telephone and permanently delete this e-mail. Thank yc::. PRIVACY: A complete copy of our privacy policy can be viewed al. Al pslAw.w.cohenoresser.com/privacL-policx EFTA00087966