From: r To: Laura Menriii (USANYS)" Cc: S) [Contractor]" (USANYS) [Contractor]" alMES> Subject: RE: US v. Maxwell - [conferral re photo and other discovery deficiencies] Date: Mon, 30 Aug 2021 23:42:05 +0000 Laura, With respect to your questions about the HC materials, as I noted in my earlier email, we do not know how the miscommunication about the number of images happened. Somehow that number was relayed incorrectly to me from the FBI during my verbal conversations with them. I have confirmed, however, that the correct number of images was saved on the hard drives that were made available to you for review during your trip to New York. In other words, although I was told (and relayed to you) that there was a much smaller number of HC images, the correct number of images (M., the number indicated in the 302) was contained on the hard drives made available to you for your review at 500 Pearl in the spring. The HC images come from two sources: First, there were HC images recovered from the CDs seized from Epstein's New York residence. Second, there were HC images and videos recovered from the electronic devices seized from Epstein during his arrest, the search of his New York residence, and the search of his Virgin Islands residence. The first category of HC images was made available for your client and defense counsel to review at the MDC int eh fall. The first and second categories were both made available for your client and defense counsel to review at 500 Pearl Street in the spring. My understanding from the FBI is that the drive that was sent to Colorado provides the HC images in html files, similar to those contained in the recent production of confidential images dated August 5, 2021. You can refer to the images by the title of the html file in which they are saved and the row number in which they appear within that html file. These files are not Bates stamped because we are not permitted to save them on the U.S. Attorney's Office's system, so our paralegals cannot stamp them. Our team is continuing to assess what, if any, HC images we may seek to offer at trial. As soon as the team has made a final decision on that score, we will let you know. Given the many moving pieces with trial preparation, however, I cannot provide a more definite timeline at this point. Best, Assistant United States Attorney Southern District of New York 1 St. Plaza New York, NY 10007 EFTA00075650



