• SCM_GM_00006081 — SCM_GM_00006096 (Southwest records) • SCM_GM_00008138 - SCM_GM_00008146 (United Airlines records) Can you let us know if these are your redactions and, if so, why they are necessary given the protective order? Thanks, Chris From: [mailto: Sent: Monday, August 17 2020 9:48 AM To: Christian Everdell; ); Cc: Mark S. Cohen; Jeff Pagliuca; 'Laura Menninger'; Thomas J. Powers Subject: RE: Discovery Chris, We will work with our paralegals and IT staff to prepare replacement documents for the ranges you identified, and we will inquire about your suggestion of producing these materials without the McAfee encryption software. We are happy to discuss any redactions that you believe should be removed. Would you please let us know what bates ranges you are referring to? Thanks, Assistant United States Attorney Southern District of New York New York, NY 10007 From: Christian Everdell Sent: Monday, August 17, 2020 2:44 AM To: Cc: Mark S. Cohen Subject: Discovery > Thomas J. Powers Jeff Pagliuca C ; 'Laura Menninger' We noticed a few errors in the most recent production. They are similar to the errors we experienced with the first production — i.e., the file names were too long, which caused a problem uploading the files. Can you please provide replacement documents for the following Bates ranges: 1. SDNY_GM_00086557 - SDNY_GM_00096055 2. SDNV_GM_00164920 - SDNY_GM_00165517 EFTA00074701

I think these problems are caused by the McAfee encryption software that you are using. If we provided you with a hard drive with onboard encryption, would you be able to do away with the McAfee encryption software? Also, we have noticed that many of the documents in the production contain redactions. There is no reason why the documents need to be redacted, given the protective order. Can you produce unredacted copies? Thanks, Chris Christian Everdell COHEN & GRESSER LLP NewY rk. NY 10022 view bio www.cohengresser.com New York I Seoul I Paris I Washington DC I London CONFIDENTIALITY NOTICE: The information contained in this e-mail may be confidential and/or ptivileged. This e-mail is intended to be reviewed initially by only the individual named above. II the reader of this e-mail is not the intended recipient or a representative of the intended recipient. you are hereby notified that any review. dissemination or copying of this e-mail or the information contained herein is prohibited. If you have received this e-mail in error. please immediately notify the sender by telephone and permanently delete this e-mail. Thank you. PRIVACY: A complete copy of our privacy policy can be viewed a! httpslAvww.cohengressercom/privacy-policy EFTA00074702