EFTA00032465.pdf

Type: pdf
Source set: data-set-8
Extracted text

From: Laura Menninger <Imenninger(uhinflawcom> 
To: " 
y" 
, " 
)" 
(USANYS)" 
Cc: Jeff Pagliuca <jpagliucaghinflavv.com>, "Christian R Everdell - Cohen & Gresser LLP 
(ceverdellgcohengresser.com)" <ceverdellgcohengresser.com>, 'BOBBI C STERNHEIM' 
<bcstemheimgmac.com> 
Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential 
materials, scenes 
Date: Fri, 02 Apr 2021 21:35:30 +0000 
Inline-Images: image001.jpg 
Thank you for your email. Your proposal is largely acceptable to us, with the following modifications and clarifications. 
• For the items that you propose below to exclude from the evidence transported to 500 Pearl Street (with the 
exception of the cash held at 26 Federal Plaza), we will need to have access for a lawyer, investigator and paralegal 
to inspect and photograph those items at the Bronx warehouse. This seems to include the bulky items, electronic 
devices and "fragile" items. 
o Once they are photographed and shared with the team and our client, we can decide whether a separate 
inspection by our client and/or any expert is necessary at a later time. To be clear, the government's photos 
of these same items are insufficient. 
o If there are any items we are not permitted to photograph (and perhaps you will be able to tell us by April 5 
which those are), we likely will need to have those transported because there is no way for our client to 
inspect the evidence. We can wait to finalize this issue until you have finished deciding what items you 
consider non-photographable, and if we can't agree, then discuss next steps. 
o Please let us know when these "non-transportable" items can be inspected and photographed at the Bronx 
warehouse. It makes sense that it would be done soon so that we can raise any issues as necessary with the 
Court. 
• For playing any of the electronic media, we will obtain the necessary equipment to play at 500 Pearl Street and 
seek permission to bring those devices into the Courthou…
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