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 continui

nd 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) Sent: Wednesday, Augus

ou referenced. In any event, I am looking into the issue. • I am similarly working with our vendor to understand how to best identify for you which Bates number corresponds with the metadata in the index contained in the Excel spreadsheets. • Can you please provide me with a list of the photos that y

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, Southern District of New York I St. Plaza New York NY 10007 From: Sent: Friday, April 23, 2021 1:44 PM To: La

ou referenced. In any event, I am looking into the issue. • I am similarly working with our vendor to understand how to best identify for you which Bates number corresponds with the metadata in the index contained in the Excel spreadsheets. • Can you please provide me with a list of the photos that y

e 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. • Alth

emheim 33 West 19th Street-4th Fl. New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Counsel: Due to an error in Bates stamping, today we are reproducing the materials listed in the below index. These items were originally produced with incorrect Bates numbers that r

to an error in Bates stamping, today we are reproducing the materials listed in the below index. These items were originally produced with incorrect Bates numbers that resulted in overlaps. These errors have now been corrected. These discovery materials are now stamped with the correct control numbers

West 19th Street-4th Fl. New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Counsel: Due to an inadvertent error in Bates stamping in prior productions, which the Government just discovered, today we are reproducing the materials listed in the below index. These items

e Government just discovered, today we are reproducing the materials listed in the below index. These items were originally produced with incorrect Bates numbers that resulted in overlaps. These errors have now been corrected. These discovery materials are now stamped with the correct control numbers

ou referenced. In any event, I am looking into the issue. • I am similarly working with our vendor to understand how to best identify for you which Bates number corresponds with the metadata in the index contained in the Excel spreadsheets. • Can you please provide me with a list of the photos that y

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 1 St. Plaza New York, NY 10007 From: Sent: Fri

up. Please send the documents to the FTP link below: https://cohengressersharefile.com/r-r16397a3bc183400da73b8Ocbfa691256 Also, we are missing the Bates ranges listed below. SDNY_GM_00167911 through SDNY_GM_00168477 SDNY_GM_00168488 through SDNY_GM_00169165 SDNY_GM_00169184 through SDNY_GM_00169491

om Rodgers. We produced those two documents in the form in which we received them. 6. Our paralegals are working on the issues you identified with Bates ranges and metadata load files. I will reach back out to you once I have an update on the status of those issues. 7. We do not have a more detaile

ooking into the issue. I understand from your subsequent email that the Excel spreadsheet at 467566 does not have any content. Are there any other "Bates-stamped" documents without content? • I am similarly working with our vendor to understand how to best identify for you which Bates number correspon

. o The index contains multiple instances of the same "file name" with different hash values. o The index does not match any particular file with a Bates stamp. o The index does not indicate which files were withheld as "highly confidential." • Many of the photo files that were provided in discovery

ooking into the issue. I understand from your subsequent email that the Excel spreadsheet at 467566 does not have any content. Are there any other "Bates-stamped" documents without content? It is possible that there are additional items that were recovered from electronic devices and storage media tha

s using Quick View Plus. If you continue to have difficulty, we can provide more specific assistance if you provide a list or even just examples of Bates numbers that present these issues. Best, From: Sent: Tuesday, May 11, 2021 11:01 PM To: Laura Menninger........al Cc: (USANYS) < >; Jeff obbi

ems to Reproduce Of course! Does this language sound okay? In recognition of the Government's ongoing discovery obligations, and due to an error in Bates stamping, today we are reproducing the materials listed in the below index. These items were originally produced with incorrect Bates numbers that

to an error in Bates stamping, today we are reproducing the materials listed in the below index. These items were originally produced with incorrect Bates numbers that resulted in overlaps. These errors have now been corrected. These discovery materials are now stamped with the correct control numbers

from the FBI regarding the discrepancy in highly confidential material count? 2. Same for the de-designated HC materials? 3. Your answer regarding Bates-stamped but content-less files only addressed those that you took off of Epstein devices. I asked about a file that your office created — an Excel s

ain. To the best of my knowledge, there are no blank files that my office created. 4. Our paralegals have been working to look into the thousands of Bates numbers you listed as unviewable at the MDC. Attached please find a spreadsheet our paralegals created providing the status of each document. You wi

to an error in Bates stamping, today we are reproducing the materials listed in the below index. These items were originally produced with incorrect Bates numbers that resulted in overlaps. These errors have now been corrected. These discovery materials are now stamped with the correct control numbers

ems to Reproduce Of course! Does this language sound okay? In recognition of the Government's ongoing discovery obligations, and due to an error in Bates stamping, today we are reproducing the materials listed in the below index. These items were originally produced with incorrect Bates numbers that

p. Please send the documents to the FTP link below: https://cohengresser.sharefile.com/r-r16397a3bc183400da73b80cbfa69f256 Also, we are missing the Bates ranges listed below. SDNY_GM_00167911 through SDNY_GM_00168477 SDNY_GM_00168488 through SDNY_GM_00169165 SDNY_GM_00169184 through SDNY_GM_00169491

om Rodgers. We produced those two documents in the form in which we received them. 6. Our paralegals are working on the issues you identified with Bates ranges and metadata load files. I will reach back out to you once I have an update on the status of those issues. 7. We do not have a more detaile

e subject of extractions by CART. As a result, these images would not have CART numbers. 7. I have asked our paralegals and vendor to look into the Bates gap and will get back to you when I have spoken to them. Best, Assistant United States Attorney Southern District of New York From: Christian Ev

s saved to a drive by the investigative team or prepared for production. 5. As indicated in our November 9, 2020 discovery letter, all images within Bates range SDNY_GM_00467566 though SDNY_GM_00514100 were seized during the 2019 searches of Epstein residences. These are the images from the CDs that w

ccessible through multiple websites, the Government has elected to produce a copy to you as a courtesy. In addition, due to an inadvertent error in Bates stamping in the prior production, which the Government just discovered, we are reproducing certain of the materials in the below index. These items

the Government just discovered, we are reproducing certain of the materials in the below index. These items were originally produced with incorrect Bates numbers that resulted in overlaps. These errors have now been corrected. These discovery materials are now stamped with the correct control numbers

p. Please send the documents to the FTP link below: https://cohengresser.sharefile.com/r-r16397a3bc183400da73b80cbfa691256 Also, we are missing the Bates ranges listed below. SDNY_GM_00167911 through SDNY_GM_00168477 SDNY_GM_00168488 through SDNY_GM_00169165 SDNY_GM_00169184 through SDNY_GM_00169491

rom Rodgers. We produced those two documents in the form in which we received them. 6. Our paralegals are working on the issues you identified with Bates ranges and metadata load files. I will reach back out to you once I have an update on the status of those issues. 7. We do not have a more detailed

from the FBI regarding the discrepancy in highly confidential material count? 2. Same for the de-designated HC materials? 3. Your answer regarding Bates-stamped but content-less files only addressed those that you took off of Epstein devices. I asked about a file that your office created — an Excel s

t of my knowledge, there are no blank files that my office created. EFTA00040811 4. Our paralegals have been working to look into the thousands of Bates numbers you listed as unviewable at the MDC. Attached please find a spreadsheet our paralegals created providing the status of each document. You wi

ain. To the best of my knowledge, there are no blank files that my office created. 4. Our paralegals have been working to look into the thousands of Bates numbers you listed as unviewable at the MDC. Attached please find a spreadsheet our paralegals created providing the status of each document. You wi

from the FBI regarding the discrepancy in highly confidential material count? 2. Same for the de-designated HC materials? 3. Your answer regarding Bates-stamped but content-less files only addressed those that you took off of Epstein devices. I asked about a file that your office created — an Excel s

a was recovered, so none is viewable. Additionally, as indicated in our November 9, 2020 discovery letter, all images within the SDNY011 load file (Bates range SDNY_GM_00467566 though SDNY_GM_00514100) were seized during the 2019 searches of Epstein residences. These are the images from the CDs that w

discovery production). As I mentioned in my email to Laura earlier today, I am working with our vendor to figure out how to best convey to you which Bates numbers correspond with which rows in the spreadsheet. • For #6: o The SDNY_GM_SUPP contain electronic files recovered from Epstein's devices. As

you referenced. In any event, I am looking into the issue. • I am similarly working with our vendor to understand how to best identify for you which Bates number corresponds with the metadata in the index contained in the Excel spreadsheets. Can you please provide me with a list of the photos that you

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. Althou