EFTA00017813.pdf
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From:
To:
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Subject: RE: US v. Maxwell, 20 Cr. 330 (AJN) - discovery production
Date: Thu, 19 Nov 2020 17:33:55 +0000
(USANYS)"
Chris,
I have asked our paralegal and IT staff how large a drive we will need, and I hope to have an answer for you by our 1:30
call today.
As for the most recent production, the hard drive contains the production prepared by our vendor, which includes
approximately 1.2 million documents. The CD contains the final portion of the responsive images from Epstein's iPhone.
So they were produced separately because they were prepared by different offices: the hard drive was prepared by the
vendor, and the CD was prepared by our paralegals.
Because we are planning to put all productions onto a single hard drive, as you requested, the files from the CD will be
included on that new drive, so Ms. Maxwell will have those files both on a CD and on a hard drive.
Best,
Assistant United States Attorney
Southern District of New York
I St. Andrew's Plaza
New York, NY 10007
From: Christian Everdell
Sent: Wednesday, November 18, 2020 10:39 PM
To:
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Cc:
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(USANYS) <
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Subject: RE: US v. Maxwell, 20 Cr. 330 (AJN) - discovery production
Thanks,
We will provide another drive to load the full production. We just have to figure out how big it needs to be. If you have
any thoughts on that, please let me know.
Also, can you explain the difference between the hard drive and the CD? Did you just need a little more space than what
the hard drive offered? Or is there a reason you put certain files on the CD? I note that the laptop does not contain a disk
EFTA00017813
drive, so I assume Ms. Maxwell will have to use the prison computer to review the files on the CD?
Thanks,
Chris
From:
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Sent: Wednesday, November 18, 2020 2:23 PM
To: Christian Everdell; Mark S. Cohen. Laura Menninger; Jeff Pagliuca; BOBBI C STERNHEIM
Cc:
);
(USANYS)
Subject: RE: US v. Maxwell, 20 Cr. 330 (AJN) - discovery production
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