EFTA00027864.pdf

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

From: "SI" 
'ale 
To: 
(USANYS) [Contractor)" alMIIM> 
Cc: '
(USANYS)" 
Subject: FW: Discovery Issues 
Date: Mon, 29 Mar 2021 18:59:01 +0000 
Attachments: SDNY_Production_Issues_2O21O329.xlsx; SlipsheetExample-SDNY_GM_00541380.pdf 
Inline-Images: image002.jpg; image004.jpg 
Hi[, 
We just received the below and attached regarding discovery in the Maxwell case. Many of these questions relate to 
productions that PAE prepared. Would you please take a look and let me know when would be a good time this week for 
a call to discuss? 
Thanks, 
From: Christian Everdell ‹
> 
Sent: Monday, March 29, 2021 2:40 PM 
To: 
) c
>; 
>"; 
(USANYS)
Cc: 'Jeff Pagliuca' <
>; Laura Menninger 
Bobbi Sternheim 
) 
Subject: Discovery Issues 
and M
—
We write to raise a few issues concerning the discovery. Below is the list of items. Please let me know if you are free for a 
call to discuss. 
1. On our last call, we asked you if we could send our client a hard drive containing the discovery that we had created 
(without the highly confidential items). You had said you would check to see if you could facilitate this. We have 
not heard back from you. Are you able to send Ms. Maxwell the hard drive? 
2. The last two productions you sent to Ms. Maxwell on disks. As you know, she cannot read disks on her laptop and 
must use the prison computer. But the prison computer cannot read some of the files. We can include these files 
on our hard drive to send to Ms. Maxwell. Otherwise, you will need to produce them on a hard drive. Please 
advise which way you would like to proceed. 
3. A number of the emails in the discovery— over 109,000 — were produced without their attachments (see tab 1 of 
the attached Excel file). Instead, the attachments appear as slip-sheets (see example attached). Please provide the 
missing attachments, if they exist. 
4. A number of electronic documents — over 110,000 —that were extracted from one of Epstein's devices, as identified 
by a CART number, have metadata that ind…
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