EFTA00021937.pdf

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

From: IS" 
To: Christian Everdell 
Cc: "Mark S. Cohen" 
Jeff Pa liuca < 
Menninlef 
Subject: RE: United States v. Maxwell, 20 Cr. 330 (AJN 
Date: Mon, 27 Jul 2020 20:43:15 +0000 
'Laura 
Pursuant to the Court's Order of this afternoon, we write to schedule a telephonic meet and confer on issues relating to a 
protective order in the above-captioned case. Please let us know what time you are available today between 5:00 p.m. 
and 8:00 p.m., or tomorrow between 9:00 a.m. and 1:00 p.m. In particular, it would be helpful to get the defendant's 
current position on the following: 
Whether you are aware of any case in any federal district in which a protective order was entered in a criminal 
case that prevented the Government from showing its own documents to prospective witnesses or their counsel 
without requiring restrictions upon those witnesses and their counsel; 
Whether you are able to describe any expected reason why it would be necessary or useful for the defendant to 
reference by name — rather than by pseudonym or other anonymized identifier — any victim in a public statement 
or publicly-docketed filing (and rather than by sealed filing, if such named identification is necessary), such that 
the Government may consider whether it can formulate language to address any such concerns, without 
conceding any right of the defendant to name any individual who has self-identified as a victim of Jeffrey Epstein 
or Ghislaine Maxwell at any time; and 
Whether the defense is willing to itself propose any language to address the Government's concerns in relation 
to the issue described immediately above, regarding the defendant's desire to be able to reference by name any 
victim in a public statement or publicly-docketed filing, without conceding that any such right exists. 
Additionally, also relating to the production of discovery, please mail, or otherwise have delivered, a 1 terabyte hard drive 
for purposes of the Government's discovery production. While we are in…
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