What is document EFTA00028102?

This is a procedural email from an Assistant United States Attorney in the Southern District of New York to Ghislaine Maxwell's defense team. The email discusses the mechanics of filing redacted versions of motions in limine—pretrial motions that seek to exclude certain evidence—ahead of Maxwell's criminal trial.

Who is mentioned in this document?

The document mentions Maxwell's defense attorneys: Christian Everdell (a former federal prosecutor who worked on the El Chapo case), Bobbi C. Sternheim (a criminal defense attorney experienced in terrorism cases), Laura Menninger, and Jeffrey Pagliuca (both Colorado-based attorneys from Haddon, Morgan and Foreman). Prince Andrew appears as an entity tag but is not directly named in the visible text.

What does this document reveal?

This document provides a window into the behind-the-scenes legal coordination that occurred before Maxwell's trial. It shows prosecutors and defense counsel working together on the redaction process for public filings, with specific guidance on which exhibits could be released publicly versus which required court sealing. This type of cooperation on procedural matters is standard practice, even between opposing legal teams in high-profile cases.

What is document EFTA00028102?

This is a procedural email from an Assistant United States Attorney in the Southern District of New York to Ghislaine Maxwell's defense team. The email discusses the mechanics of filing redacted versions of motions in limine—pretrial motions that seek to exclude certain evidence—ahead of Maxwell's criminal trial.

Who is mentioned in this document?

The document mentions Maxwell's defense attorneys: Christian Everdell (a former federal prosecutor who worked on the El Chapo case), Bobbi C. Sternheim (a criminal defense attorney experienced in terrorism cases), Laura Menninger, and Jeffrey Pagliuca (both Colorado-based attorneys from Haddon, Morgan and Foreman). Prince Andrew appears as an entity tag but is not directly named in the visible text.

What does this document reveal?

This document provides a window into the behind-the-scenes legal coordination that occurred before Maxwell's trial. It shows prosecutors and defense counsel working together on the redaction process for public filings, with specific guidance on which exhibits could be released publicly versus which required court sealing. This type of cooperation on procedural matters is standard practice, even between opposing legal teams in high-profile cases.

EFTA00028102

An internal email from prosecutors to Ghislaine Maxwell's defense team regarding the filing of redacted versions of motions in limine ahead of her criminal trial.

This October 29, 2021 email shows federal prosecutors coordinating with Maxwell's defense attorneys—Christian Everdell, Bobbi Sternheim, Laura Menninger, and Jeffrey Pagliuca—on how to handle public filings with redactions applied. The email references the government's motion in limine, Maxwell's opposition, and the government's reply, with specific instructions about which exhibits could be filed publicly and which required sealing. This procedural communication occurred just weeks before Maxwell's trial began on November 29, 2021, where she was ultimately convicted on five of six counts related to sex trafficking and conspiracy.

Key Highlights

•Sent October 29, 2021—the court-ordered deadline for filing redacted versions of motions in limine
•Coordination between SDNY prosecutors and Maxwell's full defense team including former AUSA Christian Everdell
•Reveals the careful process of determining what evidence could be made public versus sealed from view

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EFTA00028102

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Page 1 - EFTA00028102

From: To: Christian Everdell -, BOBBI C STERNHEIM Cc: Laura Menninger , Jeff Pagliuca Subject: Redactions: Government motion in limine Date: Fri, 29 Oct 2021 20:54:50 +0000 Attachments: Govemment_MILiredactedi_Final.pdf; Govemment_MIL_Exhibit_Airedacted].pdf; !Maxwellts_Response_to_Govs_Omnibus_Motns_in_Liminedredactedi_Final.pdf; Govt_Reply_Brief [redacted]_Final.pdf All, Thanks for the call this afternoon, it was helpful to work through the mechanics of filing redactions this afternoon. As we discussed, we're sending you versions of the following documents, with redactions applied: (1) the Government's motion in limine, (2) the defendant's opposition, and (3) the Government's reply. Please let us know if you would like us to add any redactions to these versions, and we'll get them filed. With respect to Exhibits: • We are attaching a proposed redacted version of Government exhibit A. • Only defense exhibits E and G can be filed publicly without redactions. • All other defense exhibits to the defense opposition should be filed under seal. Best, Assistant United States Attorney United States Attorney's Office Southern District of New York One St. Andrew's Plaza New York, New York 10007 EFTA00028102