(USANYS) [Contractor]"
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From: To: (USANYS) [Contractor]" Cc: ' (USANYS)" Subject: FW: Letter re: Discovery Date: Thu, 27 Aug 2020 22:09:28 +0000 Attachments: 2020.08.27_Letter to_Govemment_re_Unreadable_Discovery.PDF Inline-Images: image001.png; image004jpg As you go through and shorten the file names for the Maxwell discovery, please make sure to address the files listed in the attached letter from defense counsel. I'll let you know when I receive the drives they are sending. I expect we will ask IT to load the drive with on-board encryption with the full set of discovery from all three productions to date once you have shortened the file names. I expect we will use the other drive to load the reproduction of the LSJ folder. As always, please let me know if any of this doesn't make sense or if there are any issues, and thank you so much for all of your help. Thanks, From: Christian Everdel Sent: Thursday, August 27, 2020 5:00 PM To: (USANYS) ‹ > Cc: Mark S. Cohen 'Laura Menninger' u j
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(USANYS) [Contractor]"
From: To: ' Cc: " (USANYS) [Contractor]" s-M > (USANYS)" (USANYS) [Contractor)" Subject: RE: US v. Maxwell - [conferral re photo and other discovery deficiencies] Date: Wed, 11 Aug 2021 21:33:23 +0000 Attachments: Maxwell_problem_filess images_Not_Exported.xlsx Hi again, Good news, was able to run searches for those last 200 files way more quickly than anticipated. Let me know what you think of the attached spreadsheet. The Bates number column indicates a Bates number Maxwell/her counsel identified as one she had an "images not exported" issue; the "Export File" column indicates what Relativity production export it was from; and the "Relativity Search Result" column indicates what the possible issue is with the Bates number identified. Descriptions of each type of entry in the spreadsheet are below. Let me know if you have any questions. Thanks, CORRUPTED DOC W/ EXTRACTED TEXT - This indicates that the original document was corrupt but we were able to supply extracted
EFTA00018026
From: Laura Menninge
From: Laura Menninge To: ' Cc: )" USANYS " Subject: RE: US v. Maxwell - [conferral re photo and other discovery deficiencies] Date: Wed, 28 Apr 2021 16:03:52 +0000 Received. Thank you. -Laura From: Sent: Tuesday, April 27, 2021 9:35 PM To: Laura Menninger Cc: (USANYS) ) < ) ' Subject: RE: US v. Maxwell - [conferral re photo and other discovery deficiencies] Laura, Attached please find a metadata overlay for the production of images from the CDs recovered from Epstein's residence. This file contains the file name and the MDF Hash for each file, which corresponds with the information contained in the SDNY_GM_00467567 Spreadsheet. This overlay should allow your team to see which row of metadata corresponds with which Bates number in the production. Best, Southern District of New York I St. Plaza New York NY 10007 From: Sent: Friday, April 23, 2021 1:44 PM To: Laura Menninger < Subject: RE: US v. Maxwell - [conferral re photo and other discovery deficien
To: Laura Mennin er tennin e
From: To: Laura Mennin er tennin e mflaw.com>, " " • (USANYS)" Cc: Jeff Pagliuca [email protected]>, "Christian R Everdell - Cohen & Gresser LLP ([email protected])" <[email protected]>, 'BOBBI C STERNHEIM' <[email protected]> Subject: RE: US v. Maxwell - 20 Cr. 330 (MN) - Request to view evidence, highly confidential materials, scenes Date: Sat, 27 Mar 2021 22:38:06 +0000 Inline-Images: image001.jpg Counsel, Thank you for your email. Below please find our response. If this is acceptable to you, then we will proceed with arranging the logistics of having your client produced to 500 Pearl the week of April 12th and the week April 19th. We will also arrange for the FBI to transport evidence to 500 Pearl for review the week of April 12rh. Physical Evidence • It is not reasonable or feasible to insist that the FBI bring all physical evidence to 500 Pearl Street. That said, we are certainly willing to work with you to ensure that your client can revi
Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential
From: To: ' )" C )" C Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes Date: Mon, 15 Mar 2021 23:14:14 +0000 Inline-Images: image001.jpg -notes from call with in red below. From: Sent: Thursday, March 11, 20218:20 PM To:'- (NYPD)' Cc: N. (NY) (FBI) ) `z >; (USANYS) Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes Following up on this, we had a call with defense counsel, who asked a number of questions I couldn't answer. Would you please let me know the answers to the below? For the nude/partially nude highly confidential images: • How many highly confidential images are there in total, including both from the discs and from the devices? From the devices approximately 2,100 images/videos (cellebrite is on there) From the discs you previously reviewed them all (3,459), please let us know if you want us to provide to you. Small number of nud
From: '
From: ' (USANYS) [Contractor]" < To: " MIUSAIr> " (USANYS) [Contractor]" Cc: "I > " Subject: RE: [EXTERNAL] Hard Drives Date: Wed, 29 Sep 2021 14:03:29 +0000 Importance: Normal Attachments: 2021.09.29_MDC_-_Maxwell_PASSWORD.pdf; 2021.09.29_MDC_-_Maxwell_MAIN.pdf Hi M, The drive has been packaged up and left for FedEx pickup. The two cover letters are attached (also saved here) for your reference. Thanks, From: (USANYS) Sent: Tuesday, September 28, 2021 10:54 PM To: (USANYS) [Contractor] < Cc: *c > Subject: RE: [EXTERNAL) Hard Drives Hi=, (USANYS) [Contractor] Yes, please. Can you please load the drive and send it out tomorrow? Defense counsel just emailed about this so I will let them know our paralegals received the drive today (9/28) and the hard drive will be in the mail tomorrow. Thanks, From: (USANYS) [Contractor] Sent: Tuesday, September 28, 2021 1:02 PM To: (USANYS) [Contractor] Cc: Subject: RE: [EXTERNAL] Hard Drives Hi all, (USANYS) We just
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