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istian Everdell Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue, 21st Floor York 10022 cc: Mark S. Cohen, Esq. Jeff Pagliuca, Esq. Laura Menninger, Esq. EFTA00087989
the problem — namely, shortening the file paths to the documents and producing the documents on a hard drive with onboard encryption, as opposed to McAfee encryption. Later that same day, we sent you a follow-up letter listing the unreadable documents and requesting that the government immediately repr
12:48 PM EFTA00095491 To: (USANYS) < >; Cc: >; Jeff Pagliuca • Thomas J. Powers Subject: [EXTERNAL] RE: Joint Letter re: Redactions to MILs Laura Menninger Thanks, M. I will send you our proposed redactions shortly. And I will send you text for the joint letter a little later. Also, we are delivering t
e 10/11 production and send it to Ms. Maxwell at MDC as soon as possible. That should be the 10/13, 10/25, and 10/28 productions. Please do not use McAfee encryption software to encrypt the data on the drives. That causes enormous problems for us. The drive will have external encryption, so there is no
ion of highly confidential which is unlike I have seen on even child pornography cases. Thanks for your prompt attention to these matters. -Laura Laura A. Menninger I Partner Haddon, Morgan & Foreman, P.C. Denver, CO 80203 From: Sent: Tuesday, May 11, 2021 9:01 PM To: Laura Menninge Cc: (USANYS) 'ca ; <
l - [conferral re photo and other discovery deficiencies] Hi M. The defense also asked that we use the drive's built-in encryption, rather than the McAfee software we normally use, to encrypt the drive. I'm fine with that, so long as the files are encrypted on their drive, and subject to any contrary v
erials you request from the prior productions. Best, From: Christian Everdell < Sent: Monday, August 9, 2021 12:43 PM To: ) < >; Mark S. Cohen Menninger' < >; 'Jeff Pagliuca' 'Bobbi Sternheim' Cc: I< >; Subject: RE: US v. Maxwell - discovery production (USANYS) < > (USANYS) [Contractor] (USAN
production Chris, (USANYS) [Contractor]; We received the drives and have finished loading them. As you requested, the padlock drive does not have McAfee encryption software and instead uses the encryption on the drive. That drive for counsel is available to be picked up at 1 St. Andrews now. The dri
To: >; Mark S. Cohen Menninger' >; 'Jeff Pagliuca' < >; 'Bobbi Sternheim' Cc: >; (USANYS) < < (USANYS) [Contractor) Subject: RE: US v. Maxwell - discovery production I sho
axwell and the padlock drive is for counsel. We will mark them accordingly. We have had some issues in the past with extracting information from the McAfee encryption program that you use to encrypt the data on the drives. Because the padlock drive already has onboard encryption, can you not use the McA
Entities connected to both Laura Menninger and McAfee

Ghislaine Maxwell
PERSONJeffrey Pagliuca
PERSON
Jeffrey Epstein
PERSON
Michael Cohen
PERSON
Prince Andrew
PERSON
Denver
LOCATION
Christian Everdell
PERSONSouthern District
LOCATIONCohen & Gresser LLP
ORGANIZATIONBates
PERSON
Alison J. Nathan
PERSON
Colorado
LOCATION
Department of Justice
ORGANIZATIONMark S. Cohen
PERSON
Bradley Edwards
PERSON
Paul Cassell
PERSONthe Southern District
LOCATIONBobbi Sternheim
PERSON
Virginia Giuffre
PERSON
United States
LOCATION