A March 2021 email exchange between prosecutors and Ghislaine Maxwell's defense attorney Christian Everdell regarding court-ordered redactions to Exhibit 11 in the criminal case.
This is an internal legal correspondence from the Ghislaine Maxwell federal criminal case (United States v. Maxwell). The email chain shows prosecutors and Maxwell's defense team conferring about redactions to Exhibit 11 of the Government's opposition brief, as ordered by Judge Alison J. Nathan on March 18, 2021. The prosecutors note that portions of pages 118-119 quote from a document filed under seal in the related civil case before Judge Preska, asking defense counsel to confirm whether those redactions should remain. This document provides a behind-the-scenes look at how sensitive information was handled during the pre-trial phase of the high-profile Maxwell prosecution.

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From: To: Cc: Subject: RE: Meet and Confer Date: Mon, 22 Mar 2021 19:01:58 +0000 Attachments: Exhibit 1 I (Proposed Redactions Per Order).pdf; _ _ - - 2021.02.26_Govemment_Omnibus_Opposition_to_Maxwell_Defense_Motions_FINALJPr oposed_Redactions_Per_Order).pdf Inline-Images: image001.jpg; image002.jpg Thanks for your email. In accordance with Judge Nathan's order, we are writing to confer regarding Exhibit 11 and your cover letter dated March 9, 2021. Attached please find proposed redactions to Exhibit 11. We do not believe any redactions are necessary to your cover letter. We intend to the file the brief with the redactions as set forth in Judge Nathan's March 18, 2021 order, attached here for your convenience. We note that the redactions contained on pages 118 to 119 redact quotations from and references to a document that you filed under seal (Exhibit H). We understand that the quoted portions of that document are also under seal on the civil docket before Judge Preska. Given those facts, we wanted to double check with you to see whether you in fact want those redactions removed. We will defer to you on whether these should be redacted. Best, From: Christian Everdell <[email protected]> Sent: Monday, March 22, 2021 2:29 PM Subject: Meet and Confer Per Judge Nathan's order, we need to meet and confer today about proposed redactions to Exhibit 11 of your opposition and to our letter dated March 9, 2021 regarding redactions. We are free from now through the rest of the afternoon. Please let us know what works for you. Regards, Chris Christian R Everdell EFTA00019029
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