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in the most recent production, as we are having trouble viewing them. Please let me know if you have any questions. Regards, EFTA00073188 Chris Christian Everdell COHEN & GRESSER LLP 800 Third Avenue Now York NV 10077 a New York I Seoul I Paris I Washington DC I London CONFIDENTIALITY NOTICE: The informat
Maxwell at the MDC as soon as possible. Our preference would be for you to use the drive with on-board encryption so that you do not have to use the McAfee encryption that you have been using, as long as it does not substantially increase the time it will take to load the drive. As we discussed, you wil
photos" folder in the most recent production, as we are having trouble viewing them. Please let me know if you have any questions. Regards, Chris Christian Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 +1 212 707 7268 ceverdell@cohengressencom I view bio vinvw.cohengresser.com New York I
Maxwell at the MDC as soon as possible. Our preference would be for you to use the drive with on-board encryption so that you do not have to use the McAfee encryption that you have been using, as long as it does not substantially increase the time it will take to load the drive. As we discussed, you wil
not addressed expeditiously. EFTA00087988 September 21, 2020 Page 10 Thank you in advance for your attention to these matters. Sincerely, /s/ Christian Everdell Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue, 21st Floor York 10022 cc: Mark S. Cohen, Esq. Jeff Pagliuca, Esq. Laura Menninger
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
s. Maxwell will receive her drive tomorrow at MDC. Regards, Chris From: [mailto: Sent: Wednesday, August 19, 2020 5:54 PM EFTA00092273 To: ; Christian Everdell; Cc: Mark S. Cohen; Jeff Pagliuca; 'Laura Menninger'; Thomas J. Powers Subject: RE: Discovery Chris, We expect to have another discovery producti
es you requested as well. Would you please provide us with another drive for us to load? Our paralegal is not able to load the discovery without the McAfee encryption software, so it will be included in this production. For your client's review at MDC, if you provide us with another new drive, we can lo
u not use the McAfee encryption software on that drive? Please advise. Thanks, Chris From: [mailto Sent: Thursday, August 05, 2021 8:53 PM To: Christian Everdell; Mark S. Cohen. Menninger; Jeff Pagliuca; Bobbi Sternheim Cc: (USANYS); I ) Subject: US v. Maxwell - discovery production Counsel, (USANYS) [Co
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
pect that Ms. Maxwell will receive her drive tomorrow at MDC. Regards, Chris From: [mailto: Sent: Wednesday, August 19, 2020 5:54 PM To: ); Christian Everdell; Cc: Mark S. Cohen; Jeff Pagliuca; 'Laura Menninger'; Thomas J. Powers Subject: RE: Discovery Chris, We expect to have another discovery producti
es you requested as well. Would you please provide us with another drive for us to load? Our paralegal is not able to load the discovery without the McAfee encryption software, so it will be included in this production. For your client's review at MDC, if you provide us with another new drive, we can lo
redactions and, if so, why they are necessary given the protective order? Thanks, Chris From: [mailto: Sent: Monday, August 17 2020 9:48 AM To: Christian Everdell; ); Cc: Mark S. Cohen; Jeff Pagliuca; 'Laura Menninger'; Thomas J. Powers Subject: RE: Discovery Chris, We will work with our paralegals and IT
f to prepare replacement documents for the ranges you identified, and we will inquire about your suggestion of producing these materials without the McAfee encryption software. We are happy to discuss any redactions that you believe should be removed. Would you please let us know what bates ranges you
pect that Ms. Maxwell will receive her drive tomorrow at MDC. Regards, Chris From: [mailto: Sent: Wednesday, August 19, 2020 5:54 PM To: ); Christian Everdell; Cc: Mark S. Cohen; Jeff Pagliuca; 'Laura Menninger'; Thomas J. Powers Subject: RE: Discovery Chris, We expect to have another discovery producti
es you requested as well. Would you please provide us with another drive for us to load? Our paralegal is not able to load the discovery without the McAfee encryption software, so it will be included in this production. For your client's review at MDC, if you provide us with another new drive, we can lo
redactions and, if so, why they are necessary given the protective order? Thanks, Chris From: imaitto Sent: Monday, August 17, 2020 9:48 AM To: Christian Everdell; Cc: Mark S. Cohen; Jeff Pagliuca; 'Laura Menninger; Thomas J. Powers Subject: RE: Discovery Chris, We will work with our paralegals and IT staff
f to prepare replacement documents for the ranges you identified, and we will inquire about your suggestion of producing these materials without the McAfee encryption software. We are happy to discuss any redactions that you believe should be removed. Would you please let us know what bates ranges you
Entities connected to both Christian Everdell and McAfee

Ghislaine Maxwell
PERSONJeffrey Pagliuca
PERSON
Michael Cohen
PERSONLaura Menninger
PERSON
Jeffrey Epstein
PERSON
Prince Andrew
PERSONCohen & Gresser LLP
ORGANIZATIONSouthern District
LOCATION
Denver
LOCATIONMark S. Cohen
PERSON
Department of Justice
ORGANIZATION
Alison J. Nathan
PERSONBates
PERSON
Seoul
LOCATIONBobbi Sternheim
PERSON
United States
LOCATION
Colorado
LOCATIONthe Southern District
LOCATIONLeon Black
PERSON
Julie K. Brown
PERSON