Epstein Secrets

&T documents (SDNY_GM_00001015-3637) do not seem to include subscriber information for the various phone numbers. Also, the flight logs produced by David Rodgers begin at Bates number "Rodgers000028," suggesting that Rodgers000001-000027 were not produced to us. Please produce these documents to us or provide

numbers. Also, the flight logs produced by David Rodgers begin at Bates number "Rodgers000028," suggesting

rom: Christian Everdell <[email protected]> Sent: Thursday, January 7, 2021 4:13 PM To: I< >; I< >; (USANYS) < Cc: Mark I. Cohen < >; Bobbi Sternheim < Jeff Pagliuca >; 'Laura Menninger' Subject: Discovery Requests and - We write to raise a number of discovery issues. Please let us know your

ction on the court of appeals and divests the district court of its control over those aspects of the case involved in the appeal.' United States v. Rodgers, 101 F.3d 247, 251 (2d Cir. 1996) (quoting Griggs v. Provident Consumer Disc. Co., 459 U.S. 56, 58 (1982)). "The divestiture of jurisdiction rule .

Defendant. x 20 Cr. 330 (AJN) MEMORANDUM IN SUPPORT OF GHISLAINE MAXWELL'S THIRD MOTION FOR RELEASE ON BAIL Bobbi C. Sternheim Law Offices of Bobbi C. Sternheim 33 West 19th Street - 4th Floor New York, NY 10011 Phone: Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone

ill drop it off Tuesday morning. Thanks, Chris From: Sent: Friday, January 29 2021 4:4 PM To: Christian Everdell (USANYS) Cc: Mark S. Cohen; Bobbi Sternheim; Jeff Pagliuca; 'Laura Menninger' Subject: RE: Discovery Requests Chris, Our paralegals reminded me that we have produced the ranges you included

ou send these ranges via the FTP site as well? Thanks, Chris From: Sent: Friday, January AM To: Christian Everdell USANYS) Cc: Mark S. Cohen; Bobbl Sternheim; Jeff Pagliuca; 'Laura Menninger' Subject: RE: Discovery Requests Chris, Following up on this, we have now prepared all of the items you requested

happy to consider it. As a courtesy, I will note that we have provided you with all records we received from AT&T and all records we received from David Rodgers. As to your inquiry about the Bates ranges on the Rodgers documents beginning with Bates number "28", I note that the folder containing the Rodgers

provided you with all records we received from AT&T and all records we received from David Rodgers. As to your inquiry about the Bates ranges on the Rodgers documents beginning with Bates number "28", I note that the folder containing the Rodgers subpoena returns in our August 5, 2020 production include

the FTP site as well? Thanks, Chris From: [maitto Sent: Friday, January 29, 2021 10:31 AM To: Christian Everdell; (USANYS) Cc: Mark S. Cohen; Bobbi Sternheim; Jeff Pagliuca; 'Laura Menninger' Subject: RE: Discovery Requests Chris, Following up on this, we have now prepared all of the items you requested

happy to consider it. As a courtesy, I will note that we have provided you with all records we received from AT&T and all records we received from David Rodgers. As to your inquiry about the Bates ranges on the Rodgers documents beginning with Bates number "28", I note that the folder containing the Rodgers

provided you with all records we received from AT&T and all records we received from David Rodgers. As to your inquiry about the Bates ranges on the Rodgers documents beginning with Bates number "28", I note that the folder containing the Rodgers subpoena returns in our August 5, 2020 production include

happy to consider it. As a courtesy, I will note that we have provided you with all records we received from AT&T and all records we received from David Rodgers. As to your inquiry about the Bates ranges on the Rodgers documents beginning with Bates number "28", I note that the folder containing the Rodgers

provided you with all records we received from AT&T and all records we received from David Rodgers. As to your inquiry about the Bates ranges on the Rodgers documents beginning with Bates number "28", I note that the folder containing the Rodgers subpoena returns in our August 5, 2020 production include

tates Attorney Southern District of New York From: Christian Everdell < Sent: Thursday, January 7, 2021 4:13 PM To: (USANYS) Cc: Mark S. Cohen Bobbi Sternheim c >; Jeff Pagliuca >; ; 'Laura Menninger' Subject: Discovery Requests We write to raise a number of discovery issues. Please let us know your po

erdell Sent: Thursday, January 7, 20214:13 PM To: < (USANYS) Cc: Mark S. Cohen 'Laura Menninger' Subject: Discovery Requests and M— >; >; ; Bobbi Sternheim < Jeff Pagliuca We write to raise a number of discovery issues. Please let us know your position on these issues at your earliest convenience. EF

&T documents (SDNY_GM_00001015-3637) do not seem to include subscriber information for the various phone numbers. Also, the flight logs produced by David Rodgers begin at Bates number "Rodgers000028," suggesting that Rodgers000001-000027 were not produced to us. Please produce these documents to us or provide

numbers. Also, the flight logs produced by David Rodgers begin at Bates number "Rodgers000028," suggesting

FTP site as well? Thanks, Chris From: [mailto Sent: Friday, January 29, 2021 10:31 AM To: Christian Everdell; ); (USANYS) Cc: Mark S. Cohen; Bobbi Sternheim; Jeff Pagliuca; 'Laura Menninger' Subject: RE: Discovery Requests Chris, Following up on this, we have now prepared all of the items you requested

happy to consider it. As a courtesy, I will note that we have provided you with all records we received from AT&T and all records we received from David Rodgers. As to your inquiry about the Bates ranges on the Rodgers documents beginning with Bates number "28", I note that the folder containing the Rodgers

provided you with all records we received from AT&T and all records we received from David Rodgers. As to your inquiry about the Bates ranges on the Rodgers documents beginning with Bates number "28", I note that the folder containing the Rodgers subpoena returns in our August 5, 2020 production include

tian Everdell < Sent: Thursday, January 7, 2021 4:13 PM To: (USANYS) Cc: Mark S. Cohen >; 'Laura Menninger' Subject: Discovery Requests >; >; Bobbi Sternheim c >; Jeff Pagliuca We write to raise a number of discovery issues. Please let us know your position on these issues at your earliest convenience.

&T documents (SDNY_GM_00001015-3637) do not seem to include subscriber information for the various phone numbers. Also, the flight logs produced by David Rodgers begin at Bates number "Rodgers000028," suggesting that Rodgers000001-000027 were not produced to us. Please produce these documents to us or provide

numbers. Also, the flight logs produced by David Rodgers begin at Bates number "Rodgers000028," suggesting