From: Laura Menninger Sent: Tuesday, August 24, 2021 12:00 PM To: (USANYS) Cc: ) on rac or < Subject: RE: US v. Maxwell - [conferral re photo and other discovery deficiencies] >; Jeff Pagliuca (USANYS) [Contractor] We are available to review the hard-drives and boots this Thursday (8/26), next Tuesday (8/31) or on September 1st. Let me know which FBI office and any local officer I need to coordinate with for entry to the building. On the topic of HC materials, I don't believe I have yet received an explanation for statement below ("I have confirmed with the FBI that the larger number contained in the 302 is accurate. I have not been able to figure out where the disconnect arose between the actual number and the number that was verbally conveyed to me, which I then conveyed to you. I apologize for the mistake, which was unintentional."). Can someone please provide an explanation for the reason those two numbers differed so dramatically? What is the current count of HC photos? Where did all of the HC photos come from? We may need more than one session of viewing, depending on the size of the hard drives. I also may need to re-review with an expert once I have had an opportunity to view any new materials for the first time. I also likely will need to sort out a method of viewing these with my client. Finally, given the volume of HC materials, offered when we were in NY at some point to specify which if any HC materials the government seeks to introduce at trial. If you are able to do that now (prior to my review), it certainly will cut-down on the time needed to review and potential expert fees. Obviously if I am unable to view the materials in sufficient time, we may need to seek extra accommodations to complete the task, and a means of reviewing these new HC materials with Ms. Maxwell, as is her right. Let me know if those dates work and an explanation. Thank you, Laura Laura A. Henninger I Partner Haddon, Morgan & Foreman, P.C. 1501. 10th Avenue I Denver, CO 80203 From: (USANYS) Sent: Sunday, August 22, 2021 1:04 PM To: ) ; Laura Menninger Cc: Pagliuca [Contras Subject: RE: US v. Maxwell - [conferral re photo and other discovery deficiencies] Counsel, MEMieff (USANYS) EFTA00099103

We write to meet and confer about Judge Nathan's order (Dkt. No. 322) and some other issues. Please let us know if you are free to speak by phone tomorrow before 3 pm or Tuesday after 2:30 pm. Also, please let us know some dates and times that you would like to review the hard drives and boots in Colorado. Best, From: Sent: Wednesday, August 4, 2021 5:25 PM To: Laura Menninge Cc: (USANYS) < < ; Jeff Pagliuca (USANYS) [Contractor] < '; (USANYS) [Contractor] (USANYS) [Contractor] Subject: RE: US v. Maxwell - [conferral re photo and other discovery deficiencies] Laura, Thank you for your email and for your patience as I track down answers for you. By the end of this week, I expect to have a production ready for you, which will contain two categories of images responsive to the discussions we have been having: • First, the production will include several thousand images that the FBI has de-designated from Highly Confidential down to Confidential. These will be produced in a format that should provide you with all available metadata together with each image. This production is the culmination of the de-designation review process that the FBI has completed over the past few months. • Second, the production will include all of the approximately 40,000 images previously produced to you, which were extracted from CDs seized from Epstein's New York residence. This production will be in a new format that should provide you with all available metadata together with each image. For this production, we will need two 500GB hard drives (one for counsel's copy and one for Ms. Maxwell's copy) on which to load the materials. I have also discussed your request that the FBI relocate certain items to the field office in Colorado to facilitate your review. The FBI is able to make such a transfer of two of the items you requested: • The FBI will send hard drives containing the remaining highly confidential image and video files seized from Epstein's devices and CDs to Colorado, where you may review them. As was the case in New York, these will need to be reviewed on a government laptop in the presence of an FBI employee and cannot be copied, photographed, or removed from FBI property. • The FBI will also send the boots that were recently taken into evidence at 1B items to Colorado, where you may review them. You may examine and photograph the boots in the presence of an FBI employee, but they may not be removed from FBI property. • The photographs provided by cannot be shipped out of the New York office because they are logged as 1A items and must remain with the case file in New York. We are happy to arrange a time for the defense to examine those photographs in person in New York. You may examine and photograph the photos in the presence of an FBI employee, with the understanding that any photographs of these materials must be treated as Confidential under the Protective Order in this case. There are relatively few photographs, so any review of these should not be time-intensive. Both of the case agents on our team are out of the office this week and next week, but we are working to find other agents who can help us coordinate shipping the drives and the boots to Colorado. My hope is that they will get to Colorado by next week. Please let me know what date(s) you would like to review those items later this month, and I will coordinate with the FBI to schedule your review. EFTA00099104