EFTA00020322.pdf

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

From: Laura Menninger <[email protected]> 
To: /, 
111 
I 
II 
(USANYS)" 
Cc: Jeff Pagliuca [email protected]>, "Christian R Everdell - Cohen & Gresser LLP 
(ceverdell@cohengressercom)" <[email protected]>, 'BOBBI C STERNHEIM' 
<[email protected]> 
Subject: RE: US v. Maxwell - 20 Cr. 330 (MN) - Request to view evidence, highly confidential 
materials, scenes 
Date: Mon, 22 Mar 2021 21:18:42 +0000 
Inline-Images: image00 Ljpg 
All, 
We have considered your proposal. Unfortunately, it does not permit us an adequate ability to review the evidence in the 
case and does not permit our client to meaningfully participate in her own defense. 
First, we are unable to meaningfully review the evidence without the benefit of our laptops and other electronic devices 
which are needed to take notes of our review. We also need access to our devices during the review to compare the 
physical evidence with the electronic discovery and with our work product. 
Second, we need to provide our client the ability to review all discovery, including any recordings, in order to assist in her 
own defense. Presuming that she will not be taken to the FBI downtown office, then your proposal offers no means by 
which she can both inspect a recording in its physical form and listen to the recording at the same time. 
In order to address the deficiencies in your proposal, we believe the following are necessary: 
Physical Evidence 
• All of the physical evidence currently located in the FBI Bronx warehouse will be transported to 500 Pearl Street 
and made available during the week of April 12, with our client present, in a room sufficiently large to 
accommodate 8 attorneys and investigators. 
o We do not need the "bulky" massage tables transported; if there are any other extremely large evidence 
pieces, let us know what they are and we can consider whether we can have someone review and 
photograph those at the Bronx warehouse at an earlier time. 
o From your email, it appears t…
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