Epstein Secrets

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

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 the call, attached 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

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, 27 Aug 2020 20:59:45 +0000 Attachments: 202

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

ristian 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. Please let me know if you did not receive them. Please load the complete production

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

tian 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. Please let me know if you did not receive them. Please load the complete production

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

tective 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 replacement documents for the ranges you

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

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 let me know if you did not receive t

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

From: Christian Everdell Sent: Monday, August 17, 2020 2:44 AM To: Cc: Mark S. Cohen Subject: Discovery Thomas J. Powers >; ; Jeff Pagliuca 'Laura Menninger' We noticed a few errors in the most recent production. They are similar to the errors we experienced with the first production — i.e., the file nam