Epstein Secrets

COHEN & GRESSER LLP September 21, 2020 BY EMAIL , Esq. Esq. Esq. United States Attorney's Office Southern District of New York 1 St. Andrew's Plaza New York, NY

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

roduction, 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 information contained in this

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

e 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 Seoul I Paris I Wash

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

no reason why the documents need to be redacted, given the protective order. Can you produce unredacted copies? Thanks, Chris Christian Everdell COHEN & GRESSER LLP New York. NY lbuzz view bio www.cohengresser.com New York I Seoul I Paris I Washington DC I London CONFIDENTIALITY NOTICE: The information conta

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

ILs by the end of today. We have a few proposed redactions. How do you propose we handle this? Thanks, Chris Christian R Everdell EFTA00095492 COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 view bio www.cohengresser.com New York I Paris I Washington DC I London CONFIDENTIALITY NOTICE: The informa

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

no reason why the documents need to be redacted, given the protective order. Can you produce unredacted copies? Thanks, Chris Christian Everdell COHEN & GRESSER LLP NewY rk. NY 10022 view bio www.cohengresser.com New York I Seoul I Paris I Washington DC I London CONFIDENTIALITY NOTICE: The information contai

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

no reason why the documents need to be redacted, given the protective order. Can you produce unredacted copies? Thanks, Chris Christian Everdell COHEN & GRESSER LLP New York NY 10022 I view bio worw.cohengresser.com New York I Seoul I Paris I Washington DC I London CONFIDENTIALITY NOTICE: The information con

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

COHEN & GRESSER LLP September 21, 2020 BY EMAIL Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear We write to address three issues. First, we write to e

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