Thank you, Laura From: Sent: Wednesday, Au To: Laura Menninger Cc: • ; Jeff Pagliuca < (USANYS) [Contractor] (USANYS) [Contractor) Subject: RE: US v. Maxwell - [conferral re photo and other discovery deficiencies) (USANYS) Laura, The items are available for review tomorrow after 11 MDT or Wednesday, September 1, after 10:30 MDT. Please let us know when you plan to do the review so I can let the FBI agent know. The review will be at in Denver and the FBI agent is . If you need different or additional dates/times, please et us know. will get back to you on your questions about HC materials. Best, From: Laura Menninge Sent: Tuesday, August 2 , : To: (USANYS) < ) Cc: ) ‹ ; 1< :.; Jeff Pagliuca (USANYS) [Contractor) >; (USANYS) [Contractor] < Subject: RE: US v. Maxwell - [conferral re photo and other discovery deficiencies] 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. EFTA00102059