To: >; Laura Menninger Cc: < ; Jeff Pagliuca [Contra Subject: RE: US v. Maxwell - [conferral re photo and other discovery deficiencies] Counsel, (USANYS) 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 Menninger Cc: (USANYS) < I < >; 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 EFTA00080666

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. Best, Assistant United States Attorney Southern District of New York I St. Plaza New York, NY 10007 From: Laura Menninger Sent: Wednesday, July 21, 2021 7:37 PM To: Cc: )°c >; Jeff Pagliuc (USANYS) [Contractor] < >; (USANYS) [Contractor] <I >;= (USANYS) [Contractor] Subject: RE: US v. Maxwell - [conferral re photo and other discovery deficiencies] ) gc ) (USANYS) I am writing to inquire regarding the status of the NC material review and de-designation (highlighted #2 below, from May 14) and also to discuss how we may go about reviewing the additional 30,000 HC materials that we were not made available to us when we traveled to NY for that purpose. Do you know when the de-designation process will be complete? And when do you expect the de-designated documents will be disclosed? Also, regarding the remaining HC materials (highlighted #1 below), we would propose that they be made available for our review at the FBI office here in Colorado within the next 30 days. We also would like to inspect at the same time and place (a) the originals of the VRG photos that you located after our evidence review and (b) the boots that you recently took possession of. I am happy to schedule a time to discuss logistics if that would be easier. Thanks, Laura Laura A. Henninger I Partner Haddon, Morgan & Foreman, P.C. 150 1. 10th Avenue I Denver, CO 80203 EFTA00080667