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from the FBI regarding the discrepancy in highly confidential material count? 2. Same for the de-designated HC materials? 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
t of my knowledge, there are no blank files that my office created. EFTA00040811 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
St. Plaza New York, NY 10007 From: Laura Menninger Sent: Wednesday, July 21, 2021 7:37 PM To: ) c ) Cc: (USANYS) ; Jeff Pagliuc (USANYS) [Contrac or < EFTA00040810 [Contractor] (USANYS) [Contractor] Subject: RE: US v. Maxwell - [conferral re photo and other discovery deficiencies] I am wr
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
from the FBI regarding the discrepancy in highly confidential material count? 2. Same for the de-designated HC materials? 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
the hard drives and boots in Colorado. Best, From: Sent: Wednesday, Au ust 4 20215:25 PM To: Laura Menninger Cc: ) a; Jeff Pagliuca (USANYS) [Contrac or >, [Contractor] a I= (USANYS) [Contractor] < > Subject: RE: US v. Maxwell - [conferral re photo and other discovery deficiencies) Laura, Th
the images by the title of the html file in which they are saved and the row number in which they appear within that html file. These files are not Bates stamped because we are not permitted to save them on the U.S. Attorney's Office's system, so our paralegals cannot stamp them. Our team is continui
nd see how far I can get before requesting additional dates and times. In addition to my earlier questions, can you please let me know if there are Bates numbers or other production identifiers / logs for me to work off of during this review? Thank you, Laura From: (USANYS) Sent: Wednesday, Augus
uring this review? Thank you, Laura From: (USANYS) Sent: Wednesday, August 25, 2021 1:23 PM To: Laura Menninger l< Cc: )< ;Jeff Pagliuca [Contrac or >; on rac or > Subject: RE: US v. Maxwell - [conferral re photo and other discovery deficiencies] Laura, The items are available for review
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
St. Plaza New York, NY 10007 From: Laura Menninge Sent: Wednesday, July 21, 2021 7:37 PM To: ) Cc: (USANYS) )4: >; Jeff Pagliuca (USANYS) [Contrac or < [Contractor] < >; (USANYS) [Contractor] Subject: RE: US v. Maxwell - [conferral re photo and other discovery deficiencies] I am writing to i
from the FBI regarding the discrepancy in highly confidential material count? 2. Same for the de-designated HC materials? 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
nd see how far I can get before requesting additional dates and times. In addition to my earlier questions, can you please let me know if there are Bates numbers or other production identifiers / logs for me to work off of during this review? Thank you, Laura From: (USANYS) Sent: Wednesday, Augus
nver, CO 80203 From: (USANYS) .ca Sent: Sunday, August 22, 2021 1:04 PM To: ; Laura Menninger <II Cc: c MP; < I>: Jeff Pagliuca (USANYS) [Contrac , > Subject: RE: US v. Maxwell - [conferral re photo and other discovery deficiencies] Counsel, We write to meet and confer about Judge Nathan's
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? EFTA00040837 2. Same for the de-designated HC materials? 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
rives and boots in Colorado. Best, From: Sent: Wednesday, August 4, 2021 5:25 PM To: Laura Menninge Cc: < ) < >; Jeff Pagliuca >, (USANYS) [Contrac (USANYS) [Contractor] < Subject: RE: US v. Maxwell - [conferral re photo and other discovery deficiencies] Laura, Thank you for your email and fo
nd see how far I can get before requesting additional dates and times. In addition to my earlier questions, can you please let me know if there are Bates numbers or other production identifiers / logs for me to work off of during this review? Thank you, Laura From: (USANYS) Sent: Wednesday, Augus
10th Avenue I Denver, CO 80203 From: (USANYS) Sent: Monday, September 27, 2021 9:20 AM To: Laura Menninger Cc: < ; Jeff Pagliuca (USANYS) [Contrac c > Subject: RE: US v. Maxwell - [conferral re photo and other discovery deficiencies] Laura, We intend to send the boots back to New York this w
nd see how far I can get before requesting additional dates and times. In addition to my earlier questions, can you please let me know if there are Bates numbers or other production identifiers / logs for me to work off of during this review? Thank you, Laura From: (USANYS) •c A........-• x nri
& Foreman, P.C. 150 E. 10th Avenue I Denver, CO 80203 From: (USANYS) Sent: Sunday, August 22, 2021 1:04 PM To: Cc: ;Jeff Pagliuca (USANYS) [Contrac Subject: RE: US v. Maxwell - [conferral re photo and other discovery deficiencies] Counsel, We write to meet and confer about Judge Nathan's order
Entities connected to both Bates and Contrac

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSONJeffrey Pagliuca
PERSONSouthern District
LOCATIONLaura Menninger
PERSON
Denver
LOCATIONMorgan & Foreman
ORGANIZATION
Laura A. Henninger
PERSONBobbi Sternheim
PERSONLeon Black
PERSON
Colorado
LOCATION
Pearl
ORGANIZATIONDefense Counsel
ORGANIZATIONJeff Pa
PERSONLarry Visoski
PERSONBobbi Sternhei
PERSONContr
PERSON