From: Sent: Monday, April 5 To: Laura Menninger (USANYS) Cc: Jeff Pagliuca < ; Christian R Everdell - Cohen & Gresser LLP BOBBI C STERNHEIM' Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes Laura, Thank you for your email and for your understanding as we work through the logistics of arranging this review. Your modifications and clarifications are acceptable to us. Below I address each specifically: • The FBI can arrange for a lawyer, investigator, and paralegal to inspect and photograph the precluded items at the Bronx warehouse either next week or the week after. Please let us know what day you would like to arrange for that inspection, and I will coordinate with the FBI accordingly. I would suggest trying to schedule this visit early next week if possible so that if there are items that you believe need to be produced to 500 Pearl Street, we will have time to do so during a subsequent day of review at 500 Pearl if the FBI agrees to transport the item(s). • Tomorrow, I will send you evidence spreadsheets with annotations of which items the FBI will not be producing to 500 Pearl Street, and which items we are designating under the Protective Order. Please note that certain items will be designated "Confidential," in which case they may be photographed, but the photographs should be treated as Confidential under the Protective Order. Other items will be designated "Highly Confidential," in which case they may not be photographed, absent specific authorization from an AUSA. I note the possibility of authorization to photograph this latter category because some Highly Confidential evidence items include both nude and non-nude portions, in which case we would permit photography of the non-nude portions. • In light of our decision to produce non-testifying witness statements beginning on April 12, 2021, we are no longer segregating any electronic media that contain witness statements during this review. This is because all of the witness statements on the electronic media in the FBI's possession are from witnesses whom the Government does not expect to call at trial in this case. Please note that we intend to produce digital audio files to you containing the contents of the electronic media with these non-testifying witness statements, but you are of course welcome to review the original recordings themselves. • In terms of space, I have been informed that we will not be permitted to conduct this review in a courtroom and will instead be required to do so in the proffer rooms. I have reserved the two largest proffer rooms available at 500 Pearl. We can use the largest proffer room for evidence review, and the slightly smaller proffer room as a private meeting space for the defense team. • Confirmed, I will ask the FBI to bring all electronic highly confidential images to 500 Pearl Street, including the 2,100 that were not previously reviewed and the electronic images that were previously provided for review at the MDC. • Confirmed, I will ask the FBI to bring the 7 hard-copy highly confidential materials to 500 Pearl Street. As I mentioned earlier today in a separate email, the FBI and AUSAs are prepared to facilitate this review beginning April 13th and continuing every day thereafter until your review is complete. I have also formally requested that the Marshals produce Ms. Maxwell to 500 Pearl Street on April 13th and every day thereafter until the review is complete. The Marshals previously confirmed their willingness to produce Ms. Maxwell for such a review in general, but they have not yet confirmed their ability to do so on any particular dates. I will let you know as soon as the Marshals inform me whether they can accommodate these specific dates. Best, EFTA00072408