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From: ' To: ' 1" cl Cc: >, Subject: RE: MCC discovery Date: Fri, 26 Jun 2020 19:46:33 +0000 Ok, can you please have them load these to Relativity? We may need to create a new database. From: Sent: Friday, June 26, 2020 3:40 PM To: Cc: Subject: RE: MCC discovery We received email files for these people on August 13. In October, we received more discs from Dave that were organized by inmate (Epstein, Ryes, Outlaw) but those can't be opened. From: Sent: Monday, June 15, 2020 10:04 AM To: Cc: < Subject: FW: MCC discovery EFTA00101304 M besidesan From: Sent: Monday, June 15, 2020 10:01 AM To: c e; Subject: RE: MCC discovery hose mbox files did we get from c= > For category (1), are any of the BOP employees people who were at least tangentially involved in the events in question? If so, given that they are in our possession, I think we should produce pursuant to the protective order, even though they are likely completely irrelevant. I definitely think we should look through category (2) to figure out what we should produce. From: )<= > Sent: Friday, June 12, 2020 5:42 PM To: Subject: MCC discovery Notwithstanding the Court's discovery order, I want to discuss whether we should be producing any of the following: 1) I believe we have mbox files for a number of BOP employees, not just our defendants. I think we only produced the defendants' mbox files. Should we be producing more, which probably include the emails we've been reviewing. 2) Is there anything in the BOP's document dumps that we need to produce? In particular, these post-suicide reconstruction reports? Assistant United States Attorney United States Attorney's Office Southern District of New York One St. Andrew's Plaza New York, New York 10007 EFTA00101305