EFTA00031332.pdf

Type: pdf
Source set: data-set-8
Extracted text

From: 
To: Laura Mennin er <Imennin e 
mflaw.com>, " 
" 
(USANYS)" 
Cc: Jeff Pagliuca [email protected]>, "Christian R Everdell - Cohen & Gresser LLP 
(ceverdell®cohengressercom)" <ceverdell®cohengresser.cotn>, 'BOBBI C STERNHEIM' 
<[email protected]> 
Subject: RE: US v. Maxwell - 20 Cr. 330 (MN) - Request to view evidence, highly confidential 
materials, scenes 
Date: Fri, 09 Apr 2021 02:05:26 +0000 
Inline-Images: image001.jpg 
Laura, 
Below please find responses to the issues you raised: 
• We are confirmed for the review at the Bronx warehouse on April 12, 2021 from 11am to 4:30pm. 
• During the April 12th review, your team can see the evidence for yourselves and let me know if you need any of the 
items you are not permitted to photograph to be brought to 500 Pearl. Depending on the size of the item(s), we 
may need to figure out whether they can be brought later in the week once you have already reviewed several 
boxes, which would free up space in the FBI vehicle for the larger items. I'm confident we will be able to reach a 
reasonable agreement about those items. 
• For the bulky photos, you will not be permitted to photograph any that feature nudity. As referenced above, once 
your team has seen those photos for yourselves, you can let me know if you will need any to be brought to 500 
Pearl. 
• As I mentioned previously and is indicated in the spreadsheet, we are preparing a letter to defense counsel 
explaining why you will not be permitted to review those 16 discs. We expect to send you that letter tomorrow, 
after which I will be happy to discuss the matter further. 
• The blue-ray discs referenced in the spreadsheet are what the FBI burned in order to provide the USAO SDNY with 
a copy of electronic data to produce to you in discovery. The discs are not evidence themselves. The data is the 
evidence, and it was produced to you already. You are correct, however, that the 4/24/07 file is a data file that was 
copied from a VHS tape, which is current…
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