Epstein Secrets

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

Haddon, Morgan & Foreman, P.C. 0203 From: Sent: Tuesday, May 11, 2021 9:01 PM To: Laura Menninger Cc: (USANYS) Jeff Pagliuca EFTA00075630 Bobbi Sternhei Subject: RE: US v. Maxwell - [conferral re photo an o ier iscovery e iciencies Laura, I have responded to your comments below in red. I am workin

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

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

will produce them to you. Best, From: Laura Menninger < Sent: Friday, May 7, 20214:43 PM To: EFTA00099108 Cc: (USANYS) < ; Jeff Pagliuca • 'Bobbi Sternhei > Subject: RE: US v. Maxwell - [conferral re photo and other discovery deficiencies) Thank you for your response of April 23. I haven't heard back

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

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

ninger I Partner Haddon, Morgan & Foreman, P.C. , CO 80203 From: Sent: Thursday, May 20, 2021 6:15 PM To: Laura Menninger Cc: Jeff Pa iuca , 'Bobbi Sternhei U N ontractor (USANYS) [Contractor] Subject: RE: US v. Maxwell - [conferral re photo and other discovery deficiencies] Laura, Thank you for you

ooking into the issue. I understand from your subsequent email that the Excel spreadsheet at 467566 does not have any content. Are there any other "Bates-stamped" documents without content? It is possible that there are additional items that were recovered from electronic devices and storage media tha

. o The index contains multiple instances of the same "file name" with different hash values. o The index does not match any particular file with a Bates stamp. o The index does not indicate which files were withheld as "highly confidential." • Many of the photo files that were provided in discovery

From: Sent: Tuesday, May 11 2021 9:01 PM To: Laura Menning Cc: >. Jeff Pa liuca 'Bobbi Sternhei >; < >• Subject: RE: US v. Maxwell - [conferral re photo an of er iscovery e iciencies Laura, I have responded to your comments below in red.

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

flect the substance of the 3D scan. Best, From: Laura Menninger Sent: Tuesday, May 18, 2021 12:21 PM To: Cc: (USANYS) < >; >; Jeff Pa liuca 'Bobbi Sternhei Subject: RE: US v. Maxwell - [conferral re photo a Following up on the below, as I believe these are the outstanding issues from this email chain.

ooking into the issue. I understand from your subsequent email that the Excel spreadsheet at 467566 does not have any content. Are there any other "Bates-stamped" documents without content? It is possible that there are additional items that were recovered from electronic devices and storage media th

overed attachments, even though many did not have content. • I am similarly working with our vendor to understand how to best identify for you which Bates number corresponds with the metadata in the index contained in the Excel spreadsheets. We received your overlay on April 27. On April 28, I wrote y

on this score, I will reach out. Best, From: Laura Menninger Sent: Wednesday, April 21, 2021 1:42 PM To: Cc: (USANYS) < ) < ; Jeff Pa liuca 'Bobbi Sternhei Subject: US v. Maxwell - [conferral re photo and of er iscovery e icienctes I'm writing to follow-up on our discussion last Thursday regarding the

. o The index contains multiple instances of the same "file name" with different hash values. o The index does not match any particular file with a Bates stamp. o The index does not indicate which files were withheld as "highly confidential." • Many of the photo files that were provided in discovery

From: Laura Menningeil Sent: Wednesday, April 21, 2021 1:42 PM To: Cc: (USANYS) < ›; ; Jeff Pagliuca 'Bobbi Sternhei Subject: US v. Maxwell - [conferral re photo and o er iscovery e iciencies I'm writing to follow-up on our discussion last Thursday regarding the p