SDNY prosecutor emails on the Maxwell suppression hearing and e-discovery production

From:	(USANYS)“
To:	(USANYS)“
	Subject: RE: Question re AJN/Maxwell Suppression Hearing

Date: Wed, 16 Jun 2021 19:54:46 +0000¶

• Attachments: Ex._H_Sealed.pdf Here it is — Ex H.

From: (USANYS) Sent: Wednesday, June 16, 2021 3:45 PM To: (USANYS) Subject: RE: Question re AJN/Maxwell Suppression Hearing¶

And can you send me MJ Netbum’s decision? Exhibit Ito the def motion, I think¶

From: (USANYS) Sent: Wednesday, June 16, 2021 11:58 AM
(USANYS) < To: Cc: (USANYS) Subject: RE: Question re A1N/Maxwell Suppression Hearing
the plaintiff in the civil action. Pottinger was a lawyer at Boies Schiller who represented
The two letters we submitted in connection with our All Writs Application are attached.

From: (USANYS)
Sent: Wednesday, June 16, 2021 11:53 AM
To: (USANYS)
Subject: RE: Question re AJN/Maxwell Suppression Hearing

Another Q: who’s Stan Pottinger?¶

From:	(USANYS)
	Sent: Wednesday, June 16, 2021 10:53 AM
To:	(USANYS)
Cc:	(USANYS)

Subject: RE: Question re A1N/Maxwell Suppression Hearing¶

From:	( USANYS)
	Sent: Wednesday, June 16, 2021 10:40 AM
To:	(USANYS)
Cc:	(USANYS) ‹	>

Subject: RE: Question re A1N/Maxwell Suppression Hearing¶

Can I see our original application to Judge Sweet? And I assume there was no transcript before Judge S?¶

From: (USANYS)
Sent: Tuesday, June 15, 2021 5:45 PM
To: (USANYS) <
Cc: (USANYS) (USANYS) <
Subject: RE: Question re AJN/Maxwell Suppression Hearing
In the spirit of completeness, I’m also attaching their replies.
From: (USANYS)
Sent: Tuesday, June 15, 2021 5:20 PM
ire To: (USANYS)
Cc: >; (USANYS) < (USANYS)
Subject: Re: Question re AJN/Maxwell Suppression Hearing
Goodness!
Associate U.S. Attorney
Southern District of New York
On Jun 15, 2021, at 5:06 PM, wrote: (USANYS) <

She filed 12 (!!) separate MOLs as a way to evade the Court’s page limits. Defense attorneys have started doing that over the last few years.¶

From: (USANYS) <
Sent: Tuesday, June 15, 2021 4:25 PM
To: (USANYS)
Cc: (USANYS)	(USANYS) <
Subject: RE: Question re AJN/Maxwell Suppression Hearing
Dumb Q: why does Maxwell have two memos of law?
From: (USANYS)
Sent: Tuesday, June 15, 2021 2:19 PM
To: (USANYS) <
Cc: (USANYS)	(USANYS) <
Subject: RE: Question re AJN/Maxwell Suppression Hearing

Per our discussion, I am attaching: (1) Maxwell’s two briefs raising the suppression argument; (2) the transcript of the McMahon proceedings and her opinion (Ex D, E, G); (3) our brief (see pp 59-115); and (4) the exhibits we attached to our motion (Ex 4-7). Judge Nathan has said that she will resolve the suppression motions “at a later time” ahead of trial. Thanks very much.¶

From:	(USANYS)
Sent: Tuesday, June 15, 2021 10:09 AM
To:	(USANYS)

; (USANYS) < Cc: (USANYS) Subject: RE: Question re AJN/Maxwell Suppression Hearing
Sure, set a time other than 2:00. I’m in the office. Or Webex
From: (USANYS) Sent: Tuesday, June 15, 2021 9:11 AM (USANTS) < To: I (USANYS) ; Cc: (USANYS) < Subject: Question re AJN/Maxwell Suppression Hearing

Hi=,¶

We had an issue come up related to the upcoming suppression hearing (no date set yet, although we expect one) related to that we’d like your thoughts on. Let us know a convenient time to stop by over the next few days, thanks.¶

Chief, Public Corruption Unit U.S. Attorney’s Office Southern District of New York¶

Thanks, We appreciate the help. I know this has been a big headache and created a lot of problems not just for us but for a number of other units, and we really appreciate you trying to get us across the finish line.¶

From: (USANYS) <
Sent: Friday, October 30, 2020 2:42 PM
To: (USANYS)	(USANYS)
Subject: RE: Phone Call Follow-Up
Understood
(USANYS) <ma From:</ma
Sent: Friday, October 30, 2020 2:41 PM
To: (USANYS)	(USANYS) <	•
Subject: RE: Phone Call Follow-Up

Thanks, The problem is the stuff that is coming today is stuff the team asked PAE to process in early September. I realize that this is a big project and that there’s only so much that can be done, but it poses almost insurmountable timing hurdles for our team if it is taking 1-2 months for PAE to get us stuff we ask for out of Relativity. In most of our cases, this one included, that eats up a huge chunk of the time we have available to produce discovery.¶

We’ll follow up early next week to see if there is a more concrete update, but I think this may require a broader or higher level explanation to the Court. I am concerned about requiring our team to take the hit with Judge Nathan for missing this deadline.¶

From: (USANYS) <	>
Sent: Friday, October 30, 2020 12:51 PM
To: (USANYS)	(USANYS)
Subject: FW: Phone Call Follow-Up

Some of the data is being sent to use today by FedEX. However, there is a ton of stuff still being processed. That stuff is still being imaged. Then it gets marked. Then copied to us. I have spoken to He thinks it is not possible to meet the November 9 date. He thinks the next step might be done on Tuesday, and then a better estimate of completion might be possible.¶

•
From:-[US]	M) “:1
	Sent: Friday, October 30, 2020 12:25 PM
To:	(USANYS)
Cc:	(USANYS) [Contractor] <	>
Subject: Phone Call Follow-Up

Good Afternoon¶

Following up on our earlier phone conversation, a hard drive with the following productions is being sent to SDNY via FedEx with the following productions in the US v. Epstein workspace:¶

• 1. SDNYPROD008
• 2. SDNYPROD009
• 3. SDNYPROD010
• 4. SDNYPROD011 (Note: this is a six-part production)
• 5. SDNYPROD012
• 6. SDNYPROD013
• 7. SDNYPROD014

There are approximately 1.2 million records currently being imaged. The images will be available on Monday November 2 2020 at the earliest. The production of the records will begin as soon as the images are available in the workspace.¶

Please feel free to contact me if you have any questions.¶

Thanks,¶

Lead E-Discovery Analyst¶

IMPORTANT: The information contained in this message may be privileged, business sensitive, proprietary, copyrighted, protected from disclosure and/or subject to US export controls. If you are not the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please notify me immediately by replying to the message and deleting it from your computer. #-SEC-#¶