Epstein Secrets

sues, and thank you so much for all of your help. Thanks, From: Christian Everdel Sent: Thursday, August 27, 2020 5:00 PM To: (USANYS) ‹ > Cc: Mark S. Cohen 'Laura Menninger' u j : e er re: iscovery Jeff Pagliuca Thank you for the call regarding Ms. Maxwell's discovery at the MDC. As I mentioned on t

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

From: Christian EverdeII crEverdellciCohenGresser.corn> To: " (USANYS)" Cc: "Mark S. Cohen" <mcohen@CohenGressercom>, 'Laura Menninger' <[email protected]>, Jeff Pagliuca [email protected]> Subject: Letter re: Discovery Date: Thu,

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

ion 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, 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

ly Maxwell's firm dropped off two drives today. Did anyone receive them? From: Christian Everdell Sent: Thursday, August 20, 2020 3:55 PM To: Cc: Mark S. Cohen ; Thomas J. Powers Subject: RE: Discovery Jeff Pagliuca >; >; 'Laura Menninger' Tom Powers dropped off two hard drives earlier this afternoon.

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

th whatever materials 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) [Contrac

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 produc

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

ll's firm dropped off two drives today. Did anyone receive them? From: Christian Everdell Sent: Thursday, August 20, 2020 3:55 PM To: >; <I Cc: Mark S. Cohen Subject: RE: Discovery Thomas J. Powers >; Jeff Pagliuca 'Laura Menninger' Tom Powers dropped off two hard drives earlier this afternoon. Pleas

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

hey 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 staff to prepare replace

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

drives today. Did anyone receive them? From: Christian Everdell <[email protected]> Sent: Thursday, August 20, 2020 3:55 PM To: <->; Cc: Mark S. Cohen Jeff Pa liuca ; 'Laura Menninger' Thomas J. Powers Subject: RE: Discovery Tom Powers dropped off two hard drives earlier this afternoon. Please

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

y 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 to prepare replacem

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