Epstein Project

EFTA00029138.pdf

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pdf
Source set
data-set-8

Original source

Extracted text

From: ' 
To: Laura Mennin. er • 
Bobbi Sternheim 
Jeff Pagliuca 
"'BOBBI C STERNHEIM"' 
, "Mark S. Cohen" 
Cc: 1=pleMIE>
USANYS " 
Subject: RE: US v. Maxwell, 20 Cr. 330 (AJN) - meet and confer 
Date: Thu, 29 Apr 2021 23:00:26 +0000 
Attachments: 2021-04-30_Govit_Letter_to_Manleyidraft_to_defense).pdf 
Counsel, 
Regarding Mr. Manley's letter, I'm attaching a draft of the letter we would plan to him tomorrow. Please let us know if 
you'd like to confer further about this, and we'd be happy to schedule a call for tomorrow. 
Thanks, 
From: Laura Menninger 
Sent: Wednesday, April 28, 2021 6:13 PM 
To: 
Bobbi Sternheim 
'BOBBI C STERNHEIM' 
Jeff Pagliuca 
< 
Cc: 
) 
Mark S. Cohen c
>
Subject: RE: US v. Maxwell, 20 Cr. 330 (AJN) - meet and confer 
(USANYS) C
> 
Thanks for reaching out. We probably are best served by sending you our position on defense disclosures by email. We 
should be able to send that by Friday and can schedule a time to talk thereafter if you wish, with an eye towards the joint 
filing on Monday. 
We will confer with the team on the Speedy Trial issue and also get back to you on that. 
Lastly, do you want to discuss anything regarding Mr. Manley's application to the Court? I believe we are to discuss and 
then you are to write the Court by Friday. I am free tomorrow afternoon to discuss if you wish. 
Thanks, 
Laura 
Laura A. Henninger I Partner 
Haddon, Morgan & Foreman, P.C. 
From: 
< 
Sent: Tuesday, April 27, 2021 10:22 PM 
EFTA00029138


To: 
8obbi Sternheim 
;'8O681 C 
STERNHEIM' < 
s; Laura Menninger 
>; Jeff Pagliuca 
4 
>; Mark S. Cohen 
Cc: 
(USANYS) < 
>; 
Subject: US v. Maxwell, 20 Cr. 330 (MN) - meet and confer 
Counsel, 
Per Judge Nathan's Order (docket number 250), is there a time this week when you would be available for a call to meet 
and confer regarding a proposed schedule for defense disclosure of witness statements pursuant to Rule 26.2? Or if you 
would prefer to confer by email, would you please let us know your position? 
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