From: To: [Contractor (USANYS) [Contractor]" (USANYS) (USANYS) [Contractor]" Cc: ' " < (USANYS)" Subject: RE: Discovery Issues Date: Wed, 12 May 2021 13:36:03 +0000 Inline-Images: image001.jpg; image002.jpg From: Sent: Tuesday, May 11, 2021 10:41 PM To: (USANYS) [Contractor] c (USANYS) [Contractor] and I are both available anytime today. Cc: Subject: FW: Discovery Issues Hi team, (USANYS) [Contractor] •< > (USANYS).ca Maxwell's attorneys have asked for the below-listed information from the SUPP production that went out on November 9, 2021. Is there a time tomorrow when we can have a call to discuss, please? Thanks, From: Laura Menninger Sent: Friday, May 7, 2021 4:53 PM To: ) < ; 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 EFTA00096503