From: Sent: Tuesday, May 11, 2021 9:15 PM To: Laura Menninger <[email protected]>; (USANYS) Cc: Jeff Pagliuca <[email protected]>; '[email protected]' <[email protected]>, 'Bobbi Sternheim ([email protected])' <[email protected]> Subject: RE: US v. Maxwell - [conferral re photo and other discovery deficiencies] Laura, I have consulted with the FBI and our vendor regarding the issues you raised with the overlay. Below is what I understand from them: • When using the overlay, you should require only a match of the hash value. • When our vendor uses the overlay, they do not see any production numbers that do not have a match in the index. If you are still seeing outliers, please let us know which files are not matching up with the index, and our vendor will look into what that issue could be. • The 17 files with no hash values were either incomplete files or corrupt files when they were recovered from the CDs. We produced them to you so that you would have a copy of every file on the CDs that did not have identifiable nudity. • Any non-unique hash values are duplicate files. There were many duplicate files on the CDs. The FBI and vendor did not de- duplicate the images before producing them in an effort to ensure that you had a complete set of all files recovered from the CDs. • There are a number of files that were recovered from the CDs but are unopenable on our end. We produced them to you so that you would have a copy of every file on the CDs that did not have identifiable nudity. If you would like to check to see if any particular files are unopenable on our end, we would be happy to check. Given the above, the FBI and the vendor believe the overlay previously provided should be sufficient to allow you to review the metadata in this production. Best, Assistant United States Attorney Southern District of New York I St. Plaza New York, NY 10007 From: Laura Menninger <Imenningerahmflaw.com> Sent: Wednesday, April 28, 2021 1:18 PM To: (USANYS) Cc:Jeff Pagliuca <jp,agliura@bniflawzgrip; '[email protected]' <rPverdell@soliengren>; 'Bobbi Sternheim (NsternheimPmac.com)'<[email protected]> Subject: FW: US v. Maxwell - 'conferral re photo and other discovery deficiencies] Thank you for sending the overlay. After review, it unfortunately does not appear sufficient to allow us to properly match the metadata to your production of native files. Based on your representations, the "Non-Nude index" located at Bates 467567 in Excel should match the Bates number native images produced at SDNY011. However: • The number of entries in the Non-Nude Index is less than the number of files produced. Although the overlay file has 40,567 entries (the same number of files in SDNY011), they don't match up to the Non-Nude Index. o When joining the overlay file to the index: EFTA00096473

• If we require a matching value for both MD5 hash and file name, there are 24,757 entries in the overlay that do not match the index. • If we require a match on the hash value and ignore file names, there are 65 production numbers that don't match the index; 17 of those don't have hash values at all. The overlay has many non-unique hash values, meaning we cannot rely on hash value alone. • The Non-Nude index also has many non-unique hash values. I think the only feasible resolution is for you to provide a new copy of the non-nude index with an added column to note the production number of each file. We also need a new index for the produced files that were not included in the prior index. Let me know if you will agree to produce these two new indices. Thank you, Laura Laura A. Henninger I Partner Haddon, Morgan & Foreman, P.C. 1501. 10th Avenue I Denver, CO 80203 +1 303 831 7364 (Office) irnenningagimilaitgom From: Sent: Tuesday, April 27, 20219:35 PM To: Laura Menninger <lmenrungPr@hmflawcom> Cc: (USANYS) ) < :.; Jeff Pagliuca <jpagliucaPhmflaw.com>; iceverdell@cohengressencom' <[email protected]>. 'Bobbi Sternheim ([email protected])' <[email protected]> Subject: RE: US v. Maxwell - [conferral re photo and other discovery deficiencies] Laura, Attached please find a metadata overlay for the production of images from the CDs recovered from Epstein's residence. This file contains the file name and the MDF Hash for each file, which corresponds with the information contained in the SDNY_GM_00467567 Spreadsheet. This overlay should allow your team to see which row of metadata corresponds with which Bates number in the production. Best, Assistant United States Attorney Southern District of New York I St. Plaza New York, NY 10007 From: Sent: Friday, April 23, 2021 1:44 PM To: Laura Menninger <[email protected]> Cc: (USANYS) ) ; Jeff Pagliuca logliuraelmflamcmp; iceverdell@cohengressencom' <rPverriellarnhengn,conp; 'Bobbi Sternheim (bcsternheirn@macsse <bcstprnheimPmacson>: (CIV) Subject: RE: US v. Maxwell - [conferral re photo and other discovery deficiencies] Laura, Our vendor has explained the issue with SDNY_GM_00467566. That file is a temporary file without content. The file that contains the content is SDNY_GM_00467567. EFTA00096474