Epstein Secrets

Subject: RE: Discovery Requests Chris, Below please find our responses. ; Bobbi Sternheim < Jeff Pagliuca 1. As we have recently discussed, Ms. Maxwell now has access to the 4TB drive containing a full set of the discovery produced to date. It took a significant amount of time to create this copy du

Jeff Pagliuca 1. As we have recently discussed, Ms. Maxwell now has access to the 4TB drive containing a full

fidavit for the cell-site simulator used to track Ms. Maxwell's cellphone before her arrest (https://www.thedailybeast.com/how- the-fbi-tracked-down-ghislaine-maxwell-alleged-madam-of-jeffrey-epstein). The article stated that the affidavit appeared in a "newly unsealed court filing." I don't recall this affidavit

ffidavit or any other materials from the criminal discovery, and whether any discovery materials were released pursuant to FOIA requests. Regards, Chris Christian R Everdell COHEN & GRESSER LLP I view bio www.cohengresser.com New York I Paris I Washington DC I London CONFIDENTIALITY NOTICE: The information contained in this

a Menninger' <[email protected]> Subject: RE: Discovery Requests Chris, Below please find our responses. 1. As we have recently discussed, Ms. Maxwell now has access to the 4TB drive containing a full set of the discovery produced to date. It took a significant amount of time to create this copy du

our responses. 1. As we have recently discussed, Ms. Maxwell now has access to the 4TB drive containing a full

fidavit for the cell-site simulator used to track Ms. Maxwell's cellphone before her arrest (https://www.thedailybeast.com/how- the-fbi-tracked-down-ghislaine-maxwell-alleged-madam-of-jeffrey-epstein). The article stated that the affidavit appeared in a "newly unsealed court filing." I don't recall this affidavit

ffidavit or any other materials from the criminal discovery, and whether any discovery materials were released pursuant to FOIA requests. Regards, Chris Christian R Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 +1 212 957 7268 ceverdellPeohengressereom I view bio www.cohengressercom New York I Paris I W

hly confidential items). You had said you would check to see if you could facilitate this. We have not heard back from you. Are you able to send Ms. Maxwell the hard drive? 2. The last two productions you sent to Ms. Maxwell on disks. As you know, she cannot read disks on her laptop and must use the pri

ve not heard back from you. Are you able to send Ms. Maxwell the hard drive? 2. The last two productions you

Y_GM_02742044 to 2742183). Was that intentional or are we missing those documents? Please let us know your responses as soon as possible. Thanks, Chris Christian R Everdell COHEN & GRESSER LLP M M. I view bio www.cohengresser.com New York I Paris I Washington DC I London CONFIDENTIALITY NOTICE: The information contained

hly confidential items). You had said you would check to see if you could facilitate this. We have not heard back from you. Are you able to send Ms. Maxwell the hard drive? 2. The last two productions you sent to Ms. Maxwell on disks. As you know, she cannot read disks on her laptop and must use the pri

ve not heard back from you. Are you able to send Ms. Maxwell the hard drive? 2. The last two productions you

Y_GM_02742044 to 2742183). Was that intentional or are we missing those documents? Please let us know your responses as soon as possible. Thanks, Chris Christian R Everdell COHEN & GRESSER LLP Eltil l I view bio www.cohengresser.com New York I Pans I Washington DC I London CONFIDENTIALITY NOTICE: The information contained

ve not heard back from you. Are you able to send Ms. Maxwell the hard drive? 2. The last two productions you

hly confidential items). You had said you would check to see if you could facilitate this. We have not heard back from you. Are you able to send Ms. Maxwell the hard drive? 2. The last two productions you sent to Ms. Maxwell on disks. As you know, she cannot read disks on her laptop and must use the pri

Y_GM_02742044 to 2742183). Was that intentional or are we missing those documents? Please let us know your responses as soon as possible. Thanks, Chris Christian R Everdell COHEN & GRESSER LLP W il l I view by) www.cohengresser.com New York I Paris I Washington DC I London CONFIDENTIALITY NOTICE: The information contained