Epstein Secrets

1:51 PM To Cc: Subject: FW: Discovery Issues See below. Would you please produce everything except the bottom four rows to counsel via FTP and to Maxwell on a CD today? And then would you please put the items from the bottom four rows into the Sixth Production TO BE PRODUCED folder? EFTA00076276 Th

, 2020. We will reproduce these as a courtesy; however, doing so would mean that an FTP site would not be feasible for sharing the documents. SDNY GM 00169184 SDNY GM 00169491 Produced on August 21, 2020 and reproduced on September 3, 2020. We will reproduce these as a courtesy; however, doing s

6. We will produce a copy of this production to Ms. Maxwell at the MDC. If you require a reproduction of the

ent: Thursday, October 29, 2020 1:49 PM Cc: Mark S. Cohen a; 'Jeff Pagliuca' 'BOBBI C STERNHEIM' Subject: RE: Discovery Issues Laura Menninger ; Thomas J. Powers Thanks for the response Why don't you produce everything but the last four rows on the FTP site. Then whenever you make your next production, you

working with our paralegals to look into your requests below. Our paralegals are also still working on the list of files that you provided that Ms. Maxwell has been unable to review at the MDC. As soon as we are able to provide an update on these issues, I will reach back out. Best, Assistant United S

These fall into the following buckets: a. SDNY GM SUPP: these have CART numbers, but were produced

king on the list of files that you provided that Ms. Maxwell has been unable to review at the MDC. As soon as

To: Christian Everdell "Thomas J. Powers" Subject: RE: Discovery Issues Date: Mon, 24 May 2021 18:49:26 +0000 Inline-Images: image001.jpg: image002.jpg , Laura Mennin er "Bobbi Sternhei

the MDC for personal hand delivery of a hard drive on Monday, which is a federal holiday. If you would like, please send us two hard drives for Ms. Maxwell. We will plan to send one of the hard drives by mail on Monday. We cannot guarantee that we will be able to have an agent personally hand deliver t

ou would like, please send us two hard drives for Ms. Maxwell. We will plan to send one of the hard drives by

rson at the MDC on Tuesday. Best, From: Christian Everdell Sent: Wednesday, September 29, 2021 11:00 AM To: (USANYS) Cc: Laura Menninger < >; Thomas J. Powers Subject: [EXTERNAL] RE: Hard Drives ) < >; Jeff Pagliuca - As a follow-up to this, we spoke tc at the MDC.Minformed us that if we want Ms. Max

(USANYS) [Contractor] We haven't received the disc back from MDC but I've burned another copy of the 9/13 production and will send it directly to Maxwell (I've confirmed the correct address to send it to courtesy of other paras with defendants at MDC). Cover letter and password letter are attached; on

e for the most recent 9/13 production to send to Ms. Maxwell. We sent it to 1 STA yesterday to attention. Can

essage: From: Christian Everdell < Date: September 24, 2021 at 10:38:55 AM EDT To: " )" c Cc:" (USANYS)" Jeff Pagliuca >, Laura Menninger >, "Thomas J. Powers" Subject: [EXTERNAL] Hard Drives and I am emailing about a few items. First, we realized we never sent you a hard drive for the most recent 9/13 p

I be available to load discovery tomorrow? Thanks! From: Sent: Thursday, August 20, 2020 4:01 PM To: Subject: FW: Discovery Hi all, apparently 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. Co

already at the MDC, we want those to remain with Ms. Maxwell in the MDC for the time being. As tomorrow is th

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. Please let me know i

ailable to load discovery tomorrow? Thanks! From: Sent: Thursday, August 20, 2020 4:01 PM To: • cza Subject: FW: Discovery Hi all, apparently Maxwell'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: Ma

already at the MDC, we want those to remain with Ms. Maxwell in the MDC for the time being. As tomorrow is th

Chris From: [mailto: Sent: Wednesday, August 19, 2020 5:54 PM To: ); Christian Everdell; Cc: Mark S. Cohen; Jeff Pagliuca; 'Laura Menninger'; Thomas J. Powers Subject: RE: Discovery Chris, We expect to have another discovery production ready to load by this Friday, August 21st. This production will inclu

ilable to load discovery tomorrow? Thanks! From: Sent: Thursday, August 20, 2020 4:01 PM To: I "• ::'; u•je : TY • luscove Hi all, apparently Maxwell's firm dropped off two drives today. Did anyone receive them? From: Christian Everdell <[email protected]> Sent: Thursday, August 20, 2020

already at the MDC, we want those to remain with Ms. Maxwell in the MDC for the time being. As tomorrow is th

tian 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 them. Please load

know when they've gone out? Thanks so much! From: Christian Everdell Sent: Monday, March 29, 2021 6:22 PM To: ) < (USANYS) Cc: 'Jeff Pagliuca' Thomas J. Powers Subject: RE: Discovery Issues >; >; • Laura Menninger >; ita Thanks, Please send the does via the link below: • Bobbi Sternheim (USANYS) [C

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

From: Christian Everdell To:" C ' ) (USANYS)" Cc: 'Jeff Pagliuca' Laura Mennin er "Bobbi Stemheim ( (USANYS Contractor . "Thomas J. Powers" Subject: RE: Discovery Issues Date: Mon, 29 Mar 2021 22:22:28 +0000 Inline-Images: image001jpg; image002.jpg Thanks, Please send the dots via t

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

om: Christian Everdell To:' Cc: Jeff Pa , Laura Mennin er "Bobbi Stemheim (USANYS) [Contractor]" (USANYS) [Contractor]" USANYS Contractor]" "Thomas J. Powers" Subject: RE: Discovery Issues Date: Mon, 24 May 2021 18:50:00 +0000 Inline-Images: image001.jpg; image002.jpg )" Great. Thanks,-. From: [mail

working with our paralegals to look into your requests below. Our paralegals are also still working on the list of files that you provided that Ms. Maxwell has been unable to review at the MDC. As soon as we are able to provide an update on these issues, I will reach back out. Best, Assistant United S

king on the list of files that you provided that Ms. Maxwell has been unable to review at the MDC. As soon as