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time periods, they are free to do so, and we may well want to do so. Also agree on drilling down on the attachment issue. Sorry for the issue with Flatley, which is really annoying. Please let us know what you learn from him when he's back tomorrow. >; (USANYS) < (USANYS) < From: Sent: Tuesday, Oc
are all that the FBI was able to extract from the devices, or whether the FBI left out parts of these files when producing them to us. I have asked Flatley for a call tomorrow morning to discuss. In the meantime, that still leaves us with a very large number of documents hitting on the search terms. Her
all of these documents responsive, but please let us know if you'd like us to take a different approach. Thanks, Assistant United States Attorney Southern District of New York One Saint Andrew's Plaza New York, NY 10007 EFTA00101125
rms (for taint extraction) a little over a month ago — have you guys been able to start review of the search warrant returns? Our understanding from Flatley is that although the AUSAs don't have the search warrant return materials because the export to Relativity has been problematic, that you guys shou
ecially for Thanks as always, please let us know if any other info from us would be helpful, and talk soon. Assistant U.S. Attorney EFTA00153662 Southern District of New York EFTA00153663
he government's original disclosure for Stephen Flatley, dated September 15, 2021. I note that yesterday you provided a supplemental notice for Mr. Flatley. That supplement was untimely. Thus, we intend to object at trial to the admission of any opinions from Mr. Flatley not included in your September
HADDON MORGAN FOREMAN November 27, 2021 United States Attorney's Office Southern District of New York Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Counsel: Haddon. Morgan and Foreman, Pc Laura A. Menninger www.hmftaw.
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