Epstein Secrets

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

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 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) De 800 Thrd Avon,* New York NY 100

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

the older drives to send future productions to the MDC. Please let us know if that is acceptable to you. Thanks, Assistant United States Attorney Southern District of New York New York, NY 10007 From: Sent: Tuesday, August 18, 2020 3:19 PM To: Christian Everdell Cc: Mark S. Cohen Subject: RE: Discovery Ch

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

d like to review those items later this month, and I will coordinate with the FBI to schedule your review. Best, Assistant United States Attorney Southern District of New York I St. Plaza New York, NY 10007 From: Laura Menninge Sent: Wednesday, July 21, 2021 7:37 PM To: ) Cc: (USANYS) )4: >; Jeff Pagli

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

p at 1 St. Andrews now. The drive for Ms. Maxwell is being shipped out to the MDC via FedEx today as well. Best, Assistant United States Attorney Southern District of New York From: Christian Everdell < Sent: Friday, August 6, 2021 12:18 PM EFTA00098334

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

ives to Paralegal Specialist at that will enable us to get the drives loaded more quickly. Best, EFTA00098335 Assistant United States Attorney Southern District of New York EFTA00098336

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

that you believe should be removed. Would you please let us know what bates ranges you are referring to? Thanks, Assistant United States Attorney Southern District of New York New York, NY 10007 From: Christian Everdell Sent: Monday, August 17, 2020 2:44 AM To: Cc: Mark S. Cohen Subject: Discovery > Thom

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

that you believe should be removed. Would you please let us know what bates ranges you are referring to? Thanks, Assistant United States Attorney Southern District of New York New York, NY 10007 From: Christian Everdell Sent: Monday, August 17, 2020 2:44 AM To: Cc: Mark S. Cohen Subject: Discovery Thomas