EFTA00021736.pdf

"We write to raise a number of discovery issues... important for Ms. Maxwell to have this drive as soon as possible to prepare her defense."

"From: Christian Everdell Sent: Thursday, January 7, 2021 4:13 PM To: (USANYS)"

"provide it as quickly as possible to Ms. Maxwell at the MDC so that she can review the materials this weekend."

"We write to raise a number of discovery issues. Please let us know your position on these issues at your earliest convenience."

"the search warrant affidavit for the cell-site simulator used to track Ms. Maxwell's cellphone before her arrest"

"We request that the government provide an unredacted version of the FBI report, dated December 6, 2006, bearing Bates number SDNY_GM_02050812-14"

"Christian R Everdell COHEN & GRESSER LLP"

"the AT&T documents (SDNY_GM_00001015-3637) do not seem to include subscriber information"

"how-the-fbi-tracked-down-ghislaine-maxwell-alleged-madam-of-jeffrey-epstein"

"the flight logs produced by [REDACTED] begin at Bates number a00028"