Subject: RE: US v. Maxwell, 20 Cr. 330 (AJN) - non-testifying witness production

From: Subject: RE: US v. Maxwell, 20 Cr. 330 (AJN) - non-testifying witness production Date: Wed, 28 Jul 2021 13:04:41 +0000 Attachments: 2021.07.28_Maxwell_Discovery_Leuendocx The production is all set to go out. I've stamped the PBSD Education Records and Epstein Photo Book confidential with the same stamp as was used for the most recent NTW batch. Attached is a drafted cover letter to go along with these materials. From: Sent: Tuesday, July 27, 2021 7:39 PM To: Subject: RE: US v. Maxwell, 20 Cr. 330 (MN) - non-testifying witness production Thanks very much, Would it be possible to please prep everything in the discovery folder here: Usa.doj.gov \ cloud \ NYS \ StAndrews \Shared \ USvEpstein-2018R01618 Discovery\GM 27 Eighteenth Production (2021-07- M) We are designating the PBS Education Records and the Epstein Photo Book confidential, so please use the new stamp we used for the most recen batch for those materials. The rest do not need a designation. If that can get done quickly, I'd be inclined to include that production on the drives for tomorrow. From: Sent: Tuesday, July 27, 2021 4:46 PM To: Cc: >: Subject: RE: US v. Maxwell, 20 Cr. 330 (MN) - non-testifying witness production The drive for defense has been loaded. The drive for Maxwell has not yet been loaded. From: Sent: Tuesday, July 27, 2021 11:19 AM To: Cc: >; Subject: RE: US v. Maxwell, 20 Cr. 330 (MN) - non-testifying witness production EFTA00104573 Hey, I have the drives and I. work on getting them loaded. Are we including anything else on the 1TB drive for Maxwell? Thanks, From: Sent: Tuesday, July 27, 2021 9:42 AM To: ;I Cc: a; Subject: Fwd: US v. Maxwell, 20 Cr. 330 (AJN) - non-testifying witness production Hi all, Would one of you please be able to track down these drives for the Maxwell NTW production? They were apparently addressed to Thanksl Begin forwarded message: From: Christian Everdell <[email protected]> Date: July 27, 2021 at 9:25:23 AM EDT To: Cc: "Bobbi Sternheim ([email protected])" <[email protected]>, Jeff Pagliuca <[email protected]>, "Mark S. Cohen" <mcohenPcohengressencom> Laura Menninger <ImenningerPhmflaw.com>, "- Subject: Re: US v. Maxwell, 20 Cr. 330 (AJN) - non-testifying witness production Hi It was addressed to Let me know if you can't find them. Sent from my iPhone On Jul 27, 2021, at 9:10 AM, wrote: Thanks very much, Chris. Who were the drives addressed to? I have not received them yet, so I'm wondering whether they might have gone to someone else's office. From: Christian Everdell <averdell@CohenGressercom> Sent: Sunday, July 25, 2021 11:22 PM To: •; Bobbi Sternheim ([email protected] <bcsternheimPmac.corn>, Jeff Pagliuca <jpagliucaPhmflaw.com>; Mark S. Cohen <mcohen@CohenGresseccom>- Laura Menninger <Imenninger(a)hmflaw.com> EFTA00104574 Cc: >; Subject: RE: US v. Maxwell, 20 Cr. 330 (AJN) - non-testifying witness production Thanks, Tomorrow morning we have a messenger deliver a 1TB hard drive for Ms. Maxwell and a 128gb thumb drive for the attorneys. Please let us know when it is ready. From: ) [mailto: Sent: Friday, July 23, 2021 5:32 PM To: Christian Everdell; Bobbi Sternheim (bcsternheim(a'mac.com); Jeff Pagliuca; Mark S. Cohen; Laura Menninger Cc: [Contractor] Subject: US v. Maxwell, 20 Cr. 330 (AJN) - non-testifying witness production Counsel, A supplemental production of non-testifying witness material is now ready to produce. Attached please find the cover letter and index accompanying this production. Because the production contains audio and video files, it is too large to produce via USA& Would you please provide our office with two drives (128 GB should be more than sufficient) for us to load with one copy for you and one copy to be sent to Ms. Maxwell at the MDC? One thing to note: as indicated in the cover letter, DOJ has recently directed our office to cease production of materials marked with the word "confidential" in order to avoid confusion with markings reserved for classified documents. Accordingly, we have noted the appropriate designation for this production by using the label, "SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17," which references the relevant paragraphs in the Protective Order governing confidential materials. Please let us know if you have any objection to this marking or would like to discuss. Thank you, Assistant United States Attorney Southern District of New York I St. Andrew's Plaza New York, NY 10007 EFTA00104575