To: "Laura Mennin er" C SANYS) [Contractor]" c Subject: RE: US v. Maxwell - [conferral re photo and other discovery deficiencies] Date: Wed, 29 Sep 2021 20:04:22 +0000 Importance: Normal Laura, I'm following up on my email as we intend to send the boots back this week. Best, From: (USANYS) Sent: Monday, September 27, 2021 4:37 PM Subject: RE: US v. Maxwell - [conferral re photo and other discovery deficiencies] Laura, We understand you would like more time with the photos and we can leave the drives there for your review. We would like to send the boots back to New York by the end of this week as it takes some time to transport. I can reach out to the FBI agent in Colorado to help coordinate a time for you to review the boots this week if you would like to provide some times. Best, From: Laura Menninge Sent: Monday, September , : Subject: [EXTERNAL] RE: US v. Maxwell - [conferral re photo and other discovery deficiencies] HM— I appreciate you reaching out before you send them back. I have just concluded a multi-week trial which hampered my ability to spend as much time with the photos and boots as I need. Can you please hold off sending them back for about 2 weeks? I will reach out again to the agent here about setting up a time later this week to continue the viewing. Thanks, Laura Laura A. Henninger I Partner Haddon, Morgan & Foreman, P.C. 150 E. 10th Avenue I Denver, CO 80203 Sent: Monday, September 27, 2021 9:20 AM To: Laura Menninger EFTA00085799

Cc: • ; Jeff Pagliuca USANYS) [Contractor >; USANYS Contractor > Subject: RE: US v. Maxwell - [conferral re photo an of er discovery deficiencies] Laura, We intend to send the boots back to New York this week, but wanted to confirm you have finished looking at them. Please let us know. Best, From: Laura Menninger Sani• Thursday August 1 1 SS AM .JULIJCUL. nC. .../J V. IVIOAVVCII [WHICH CI IC plIVW CI ILI LAU ICI uIxuveI y ucuucnuoj Thank you for getting me some dates and times. Unfortunately something else has come up in the meantime that makes today unworkable. I will plan to be there at 10:30 a.m. next Wednesday and see how far I can get before requesting additional dates and times. In addition to my earlier questions, can you please let me know if there are Bates numbers or other production identifiers / logs for me to work off of during this review? Thank you, Laura From: (USANYS) •c A........-• x nrini nSA subject: RE: us v. Maxwell - Lconterral re photo and other discovery deticienciesj Laura, The items are available for review tomorrow after 11 MDT or Wednesday, September 1, after 10:30 MDT. Please let us know when you plan to do the review so I can let the FBI agent know. The review will be at 4624 Central Denver and the FBI agent isIf you need different or additional dates/times, please let us kno will get back to you on your questions about HC materials. Best, ■ From: Laura Menninger Sent: Tuesday, August 24, 2021 12:00 PM To: (USANYS) Subject: RE: US v. Maxwell - [conferral re photo and other discovery deficiencies] C >; Jeff Pagliuca (USANYS) [Contractor) We are available to review the hard-drives and boots this Thursday (8/26), next Tuesday (8/31) or on September 1st. Let me know which FBI office and any local officer I need to coordinate with for entry to the building. On the topic of HC materials, I don't believe I have yet received an explanation for statement below ("I have confirmed with the FBI that the larger number contained in the 302 is accurate. I have not been able to figure out where the disconnect arose between the actual number and the number that was verbally conveyed to me, which I then conveyed to you. I apologize for the mistake, which was unintentional."). Can someone please provide an explanation for EFTA00085800

the reason those two numbers differed so dramatically? What is the current count of HC photos? Where did all of the HC photos come from? We may need more than one session of viewing, depending on the size of the hard drives. I also may need to re-review with an expert once I have had an opportunity to view any new materials for the first time. I also likely will need to sort out a method of viewing these with my c Finally, given the volume of HC materials, offered when we were in NY at some point to specify which if any HC materials the government seeks to introduce at trial. If you are able to do that now (prior to my review), it certainly will cut-down on the time needed to review and potential expert fees. Obviously if I am unable to view the materials in sufficient time, we may need to seek extra accommodations to complete the task, and a means of reviewing these new HC materials with Ms. Maxwell, as is her right. Let me know if those dates work and an explanation. Thank you, Laura Laura A. Henninger I Partner Haddon, Morgan & Foreman, P.C. 150 E. 10th Avenue I Denver, CO 80203 From: (USANYS) Sent: Sunday, August 22, 2021 1:04 PM To: Cc: ;Jeff Pagliuca (USANYS) [Contrac Subject: RE: US v. Maxwell - [conferral re photo and other discovery deficiencies] Counsel, We write to meet and confer about Judge Nathan's order (Dkt. No. 322) and some other issues. Please let us know if you are free to speak by phone tomorrow before 3 pm or Tuesday after 2:30 pm. Also, please let us know some dates and times that you would like to review the hard drives and boots in Colorado. ; Laura Menninge From: Cant. IA/nAnnerl.ats AI ierne• A 'Alt C•]C ORA Subject: RE: US v. Maxwell - [conferral re photo and other discovery deficiencies] Laura, Thank you for your email and for your patience as I track down answers for you. By the end of this week, I expect to have a production ready for you, which will contain two categories of images responsive to the discussions we have been having: • First, the production will include several thousand images that the FBI has de-designated from Highly Confidential down to Confidential. These will be produced in a format that should provide you with all available metadata together with each image. This production is the culmination of the de-designation review process that the FBI has completed over the past few months. • Second, the production will include all of the approximately 40,000 images previously produced to you, which were extracted from CDs seized from Epstein's New York residence. This production will be in a new format that should provide you with all available metadata together with each image. For this production, we will need two 500GB hard drives (one for counsel's copy and one for Ms. Maxwell's copy) on which to load the materials. EFTA00085801

I have also discussed your request that the FBI relocate certain items to the field office in Colorado to facilitate your review. The FBI is able to make such a transfer of two of the items you requested: • The FBI will send hard drives containing the remaining highly confidential image and video files seized from Epstein's devices and CDs to Colorado, where you may review them. As was the case in New York, these will need to be reviewed on a government laptop in the presence of an FBI employee and cannot be copied, photographed, or removed from FBI property. • The FBI will also send the boots that were recently taken into evidence at 1B items to Colorado, where you may review them. You may examine and photograph the boots in the presence of an FBI employee, but they may not be removed from FBI property. • The photographs provided by cannot be shipped out of the New York office because they are logged as 1A items and must remain with the case file in New York. We are happy to arrange a time for the defense to examine those photographs in person in New York. You may examine and photograph the photos in the presence of an FBI employee, with the understanding that any photographs of these materials must be treated as Confidential under the Protective Order in this case. There are relatively few photographs, so any review of these should not be time-intensive. Both of the case agents on our team are out of the office this week and next week, but we are working to find other agents who can help us coordinate shipping the drives and the boots to Colorado. My hope is that they will get to Colorado by next week. Please let me know what date(s) you would like to review those items later this month, and I will coordinate with the FBI to schedule your review. Best, Assistant United States Attorney Southern District of New York St. Andrew's Plaza New York, NY 10007 From: Laura Menninger Sent: Wednesday, July 2 , Sub'ect: RE: US v. Maxwell - [conferral re photo and other discovery deficiencies) I am writing to inquire regarding the status of the NC material review and de-designation (highlighted #2 below, from May 14) and also to discuss how we may go about reviewing the additional 30,000 HC materials that we were not made available to us when we traveled to NY for that purpose. Do you know when the de-designation process will be complete? And when do you expect the de-designated documents will be disclosed? Also, regarding the remaining HC materials (highlighted #1 below), we would propose that they be made available for our review at the FBI office here in Colorado within the next 30 days. We also would like to inspect at the same time and place (a) the originals of theWhotos that you located after our evidence review and (b) the boots that you recently took possession of. I am happy to schedule a time to discuss logistics if that would be easier. Thanks, Laura Laura A. Henninger I Partner Haddon, Morgan & Foreman, P.C. 150 E. 10th Avenue I Denver, CO 80203 EFTA00085802