From: ' (USANYS) [Contractor]" To: "Mir aUSANYS)" Cc: (USANYS Contractor ' (USANYS) [Contractor]" Subject: RE: Discovery Issues Date: Fri. 21 May 2021 16:14:07 +0000 Attachments: 2021.05.21MDC-Maxwell_MAIN.docx; 2021.05.2I_MDCs Maxwell PASSWORD.docx Inline-Images: image001.jpg; image002.jpg Disc is burned and ready to get sent out to MDC. Draft cover letters are attached and saved here. Please let me know if you have any revisions. Thanks, From: Sent: Thursday, May 20, 2021 10:46 PM To: Laura Menninger c:= >; Christian Everdell (USANYS) Cc: Jeff Pagliuca cc >; Bobbi Sternheim I li `t >; (USANYS) [Contractor] Subject: RE: Discovery Issues Counsel, (USANYS) [Contractor] (USANYS) [Contractor] <=a; Today we have an additional discovery production ready to send to you. This production is small enough to produce via USAfx. Please let us know if you do not already have a USAfx account, in which case our paralegals (cc'd) can assist you in creating an account. We are also sending a CD containing this production to the MDC via FedEx. Attached please find a cover letter accompanying this production. As you will see in the letter, the majority of this production consists of materials we are providing in response to your requests for additional information regarding the SUPP production (referenced in the below email exchange). I am also attaching the excel spreadsheet referenced in the cover letter to assist in your review of the materials from the SUPP production. Please let us know if you have any further questions regarding the SUPP production or if you have any difficulty accessing the materials. Best, From: Sent: Tuesday, May 11, 2021 10:42 PM To: Laura Menninger c3 >; Christian Everdell > (USANYS) > Cc: Jeff Pagliuca Bobbi Sternheim Subject: RE: Discovery Issues EFTA00028571

Laura, I am working with our paralegals to look into your requests below. Our paralegals are also still working on the list of files that you provided that Ms. Maxwell has been unable to review at the MDC. As soon as we are able to provide an update on these issues, I will reach back out. Best, Assistant United States Attorney Southern District of New York From: Laura Menninger Sent: Friday, May 7, 20214:53 PM To: ) aS; ; Christian Everdell (USANYS) Cc: Jeff Pagliuca Bobbi Sternheim Subject: RE: Discovery Issues Also following up on your response to Chris. We have had a chance to take a look at these files again. For the SUPP production, many of the files were produced as PDFs, which seems as though they were converted prior to production. As I understand it (which is admittedly limited), carved or deleted files can still contain application metadata. We request that as to the SUPP production, you: a. Provide a list of all files that were carved or deleted; b. Confirm if all those files were produced in native format or if any were converted to PDF; c. If any were converted, provide additional information including the MIME type (for all), and if available from application metadata original file name, file dates, etc. This would amount to the equivalent of the index you provided for SDNY011. d. In the absence of (b), confirm that no application metadata was recovered from those files which might indicate file creation/modified dates Please let me know if you have any questions. Thanks, Laura Laura A. Henninger I Partner Iladdon. Morgan & Foreman, P.C. Office EFTA00028572