From: Sent: Wednesday, April 7, 2021 12:09 AM To: 'Laura Menninger' <Imenninge hmflaw.com>• (USANYS) Cc: 'Jeff Pagliuca' [email protected]>• 'Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengressercom)' <[email protected]>; 'BOBBI C STERNHEIM' <[email protected]> Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes Good evening, Today, the Marshals confirmed that they will produce Ms. Maxwell to 500 Pearl Street on April 13, 2021 and every day thereafter until the evidence review is complete. My understanding is that Ms. Maxwell should arrive to 500 Pearl Street at approximately 9:30am each morning. So we are confirmed for evidence review in the proffer rooms on the 5th floor of the 500 Pearl Street courthouse beginning at 9:30am on April 13th. I will plan to be present and to continue assisting with logistics. If any questions or concerns arise, please feel free to call my cellphone at To assist in preparing for this review, attached please find annotated versions of the three evidence spreadsheets I previously emailed to you: (1) a spreadsheet of New York evidence; (2) a spreadsheet of Florida evidence; and (3) a more detailed spreadsheet of the sub-items contained in the Florida evidence spreadsheet. A couple things to note: • These spreadsheets now indicate the Protective Order designation, if any, for each item to be reviewed. As you will see, there are three mini-VHS tapes that I need to double check before assigning a final designation. I expect to be able to access a mini-VHS cassette player later this week, at which point I will be able to provide an updated spreadsheet with a confirmed designation for those three items. Additionally, please note that there is one item about which we plan to provide you with a letter later this week. • These spreadsheets also indicate where each item will be made available for the defense to review. As you will see, we have now learned that one item (consisting of shredded paper) is currently at FBI headquarters and will not be available for review next week. Please let me know if you believe you need to review that item, and I will inquire as to whether and how it can be relocated to New York. Additionally, all 1D items consist of electronic data (as opposed to 18 items, which are physical items). As is noted in the spreadsheets, the electronic data that constitute the 1D items in this case have either already been produced to you in discovery (e.g., pen register data, GPS data, and aerial footage), or are digital recordings of interviews that will be produced as non-testifying witness statements. Because these 1D items are data files stored in the FBI system, there is no corresponding physical item to produce for you to review. Please let me know when you would like to schedule a time for a smaller group from the defense team to review evidence at the Bronx warehouse. Best, Assistant United States Attorney Southern District of New York I St. Andrew's Plaza New York, NY 10007 EFTA00030022