An email thread from July 2020 discussing a proposed protective order for discovery in the criminal case against Ghislaine Maxwell.
This is an email exchange between Ghislaine Maxwell's defense attorneys (Christian Everdell, Mark S. Cohen, Jeffrey Pagliuca, Laura Menninger from Cohen & Gresser LLP) and prosecutors during pretrial proceedings. The defense team submitted revised drafts of a protective order governing how discovery materials would be handled, with Everdell requesting government approval by 5pm the following day. The email indicates ongoing negotiations between defense and prosecution over procedural matters in what would become a high-profile criminal trial. The recipient's initial response notes confusion about receiving what appeared to be identical documents rather than a redlined version showing changes.
From: ' To: ' < < >, ' Subject: FW: Protective Order Date: Thu, 23 Jul 2020 03:19:51 +0000 Attachments: 2020-07- 03GM_protective_order_for_discovery JAJN)_Revised_Defense_Edits_07.22.2020.docx; 2020-07- 03_GM_protective_order_for_discoveryJAJN)_Revised_Defense_Edits_07.22.2020)_Clea n_Copy.docx Inline-Images: image001.png; image003.jpg Am I losing my mind, or are these the exact same document? I don't see the redline. From: Christian Everdell < Sent: Wednesday, July 22, 2020 8:13 PM To: < > Cc: Mark S. Cohen ; Jeff Pagliuca < :,; 'Laura Menninger' Subject: Protective Order Attached is a revised draft of the defense's proposed Protective Order (including a redline against the government's original draft and a clean version). We did our best to incorporate the points we discussed on our last call on Monday, July 20 and to find points of common ground and agreement. Please let us know by 5pm tomorrow whether the attached draft is acceptable to the Government. Regards, Chris Christian Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY W022 I view bio www.cohengresser.com New York I Seoul I Paris I Washington DC I London CONFIDENTIALITY NOTICE: The information contained in this e-mail may be confidential and/or ptivileged. This e-mail is intended to be reviewed initially by only the individual named above. If the reader of this e-mail is not the intended recipient or a representative of the intended recipient. you are hereby notified that any review dissemination or copying of this e-mail or the information contained herein is prohibited. If you have received this e-mail in error. please immediately notify the sender by telephone and permanently delete this e-mail. Thank you. PRIVACY: A complete copy of our privacy policy can be viewed al MoslAvww.cohenqressercom/privackpolicx EFTA00021769
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