Epstein Project

EFTA00025037.pdf

Type
pdf
Source set
data-set-8

Original source

Extracted text

From: Christian Everdell < 
To: 
Subject: [EXTERNAL] RE: Draft joint proposed request to charge 
Date: Mon, 25 Oct 2021 22:58:41 +0000 
Attachments: 2021.10.25_Letter_to_Judge_Nathan_re 
Extension_of Time.DOCX 
Attached is the letter we intend to file with the Court regarding the extension to file the jury charge. It should reflect 
everything we discussed on our call earlier today. 
Please let me know if you have any issues with it as soon as you can. I'd like to file it in the next hour or so. 
Thanks, 
Chris 
From: 
Sent: Monday, October 25, 2021 2:29 PM 
To: Christian Everdell < 
>; BOBBI C STERNHEIM < 
; Jeff Pagliuca 
Cc 
Subject: RE: Draft joint proposed request to charge 
Hi Chris, 
That works. I'm around this afternoon — give me a call at 
Thanks, 
Laura Menninger 
whenever you have a minute. 
From: Christian Everdell 
Sent: Monday, October 25, 2021 1:56 PM 
To: 
BOBBI C STERNHEIM 
>; Laura Menninger 
Cc: 
Subject: (EXTERNAL] RE: Draft joint proposed request to charge 
>; Jeff Pagliuca 
I think I have a way to come to an agreement on this. I know today is extremely busy for all of us, but can you and I have a 
5 min. call to discuss? I don't think everyone from SDNY needs to be on this call, but I leave that to you. 
Thanks, 
Chris 
EFTA00025037


From: 
Sent: Sunday, October 24, 2021 3:10 PM 
To: Christian Everdell 
Laura Menninger 
; BOBBI C STERNHEIM 
;Jeff Pagliuca 
Cc: 
Subject: RE: Draft joint proposed request to charge 
Hi Chris, 
I think the answer is yes, but just to make sure: we'd file the Government's proposal on Wednesday, you'd file whatever 
redline you like on November 3. It also occurs to us that, since your redline will presumably contain new 
proposals/objections to ours and would not include our views, we'd want to file a short reply on November 5 or 8. 
We'd consent to that option and, if you like, would join your motion for that schedule. 
Thanks, 
From: Christian Everdell c 
Sent: Sunday, October 24, 2021 12:35 PM 
To: 
.
=:>; BOBBI C…

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