EFTA00020430.pdf

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

From: Christian Everdell 
To:" 
C 
' 
) 
(USANYS)" 
Cc: 'Jeff Pagliuca' 
Laura Mennin er 
"Bobbi Stemheim ( 
(USANYS Contractor 
. "Thomas J. Powers" 
Subject: RE: Discovery Issues 
Date: Mon, 29 Mar 2021 22:22:28 +0000 
Inline-Images: image001jpg; image002.jpg 
Thanks, 
Please send the dots via the link below: 
From: 
[mailto.
Sent: Monday, March 29, 2021 3:53 PM 
To: Christian Everdell; 
); 
Ii
iit.
Im
ANYS 
Cc: 'Jeff Pagliuca'; Laura Menninger; Bobbi Sternheim 
; 
Subject: RE: Discovery Issues 
Chris, 
(USANYS) [Contractor] 
Following up on point number 7, that gap would not come in between those two productions but would instead be 
contained solely in the November 18, 2020 production. If you are missing those files, the omission was unintentional, and 
we have those files available to produce immediately. If you can send a link to your ftp site, our paralegal can upload 
those materials right away. 
Best, 
Assistant United States Attorney 
Southern District of New York 
From: 
Sent: Monday, March 29, 2021 3:36 PM 
To: Christian Everdell 
>, 
(USANYS) 
Cc: 'Jeff Pagliuca' c
.>.; Laura Menninger < 
>; Bobbi Sternheim 
EFTA00020430


Subject: RE: Discovery Issues 
Chris, 
We are available for a call to discuss tomorrow between 1pm and 2pm, between 3pm and 5pm, or after 5:30pm. Please 
let us know if there is a time in those windows that would work on your end. In the meantime, below are some initial 
responses: 
1. Our supervisors have indicated that we are not permitted to send a drive that our IT department did not load to 
the MDC. As a result, we cannot provide the drive directly to the MDC. That said, I am happy to join you in asking 
the MDC to accept the drive from you. If the MDC still refuses, then my office would not object to an application to 
Judge Nathan for an order directing the MDC to accept the drive from you, though we would need to allow MDC 
legal counsel the opportunity to note their objections to Judge Nathan. 
2. The MDC recently alerted us…
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