From: Sent: Friday, April 2 To: Laura Menning Cc: (USANYS) < < >• ) .< >; Jeff Pagliuc ; 'Bobbi Sternheim >; < > Subject: RE: US v. Maxwell - [conferral re photo and other discovery deficiencies] Laura, I am working with our team as quickly as we can to address the issues you raised in the below email. In particular: • I have asked our vendor to look into the issues with SDNY_GM_00467566. When I attempt to access that document on our Relativity database, I also receive an error message saying that the document is corrupt. I am not sure what this spreadsheet is because the only two spreadsheets that I'm aware of that correspond with the SONY JR0D011 contained in the November 9, 2020 production are the two other Excel spreadsheets you referenced. In any event, I am looking 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 that do not have content. For example, as Chris and I discussed in a separate email exchange, certain attachments to emails on Epstein's devices were only partially recovered. Because they were attached to responsive emails, we produced those partially recovered 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 you back with the persistent problems despite the overlay. I do not see that you have responded to those concerns. Can you please advise? I have been working with our vendor and paralegals to look into this issue and will respond to your April 28 email shortly. • Can you please provide me with a list of the photos that you are unable to view? Once I have that list, I will check to see whether we are able to open them on our end. I am not able to provide you a list of the photos I am unable to view, for a number of reasons including my work- product protections. I can highlight the file types that are contained on the disk and perhaps your vendor can tell us which reader will work with those file types: apmaster apversion attr avi bmp bup dat data db db-journal dot ds_store EFTA00080672

f catalog ifo images #1 images 2 iphoto ivc iPB mov mpg NULL pdf png pps ps psb psd raf tif tiff tropez txt xlsx xml will forward this response to the vendor and see what, if any, assistance we can provide. • Can you be more specific in identifying photographs that you believe should have been produced but have been omitted, please? We have endeavored with the FBI to produce copies of all non-nude photographs recovered from searches of Epstein's residence to the defense, and I am not aware of any intentional omissions. See above. Without specifics, I cannot address this issue further. • I am discussing with the FBI your request that we produce all Highly Confidential images to you. I will respond to that request next week. I do not believe I received a response to this last week as indicated. Can you please update me? Please see above. • Once we have a firm trial date, I will let you know by what date I expect to be able to provide you with a list of the Highly Confidential photographs we may introduce at trial. Please advise. We will discuss this request as a team now that we have a trial date of November 29, 2021. • I am working with our paralegals to assess the list of files that your client is unable to review at the MDC. As soon as we have finished looking into those issues, I will let you know. Is there any update on this project? EFTA00080673