Epstein Secrets

that you have questions about, please let us know. Some materials were produced to us in redacted format, so it's helpful for us to discuss specific Bates ranges. Best, EFTA00092274 From: Christian Everdell Sent: Tuesday, August 18, 2020 12:33 AM To: Cc: Mark S. Cohen Subject: RE: Discovery Tho

0 3:19 PM To: Christian Everdell Cc: Mark S. Cohen Subject: RE: Discovery Chris, • Thomas J. Powers ;Jeff Pagliuca 'Laura Menninger' The four Bates ranges you've identified are flight records produced by airline companies pursuant to subpoenas that requested flight records dating back to the 199

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

ain. To the best of my knowledge, there are no blank files that my office created. 4. Our paralegals have been working to look into the thousands of Bates numbers you listed as unviewable at the MDC. Attached please find a spreadsheet our paralegals created providing the status of each document. You wi

garding the discrepancy in highly confidential material count? 2. Same for the de-designated HC materials? EFTA00098316 3. Your answer regarding Bates-stamped but content-less files only addressed those that you took off of Epstein devices. I asked about a file that your office created — an Excel s

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

ion — i.e., the file names were too long, which caused a problem uploading the files. Can you please provide replacement documents for the following Bates ranges: 1. SDNY_GM_00086557 - SDNY_GM_00096055 2. SDNV_GM_00164920 - SDNY_GM_00165517 EFTA00074701 I think these problems are caused by the McAf

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

ion — i.e., the file names were too long, which caused a problem uploading the files. Can you please provide replacement documents for the following Bates ranges: 1. SDNY_GM_00086557 - SDNY_GM_00096055 2. SDNY_GM_00164920 - SDNY_GM_00165517 EFTA00104836 I think these problems are caused by the McAf

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