| From |
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| Subject: RE: Upcoming Nineteenth Production Date: Wed, 04 Aug 2021 19:50:02 +0000 |
| Attachments: US _ v _Maxwell_Discovery_Index.xlsx; 2021.08.04_Maxwell_Discovery_Letter.docx |
| Great, thank you! |
| The entire production has now been stamped and is ready for your review. With the exception of the FBI Recovered Metadata (which is on a hard drive; we will ask to make us an internal copy of the stamped version), the rest of the production is saved here on the shared. The index is also attached and saved here. Finally, I attached a draft cover letter for defense counsel (also saved here). I’m happy to make any changes to the production, index, or cover letter as needed. |
| If it looks good to go, we can start loading the materials once the hard drives from defense arrive. Thanks so much! |
| From: |
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| Sent: Wednesday, August 4, 2021 3:26 PM |
| To: |
| Cc |
| Subject: RE: Upcoming Nineteenth Production |
| Hi M, |
| Thanks! That proposal for the stamp makes sense to me. |
| From: Sent: Wednesday, August 4, 2021 11:08 AM |
| To: |
| Cc |
| Subject: RE: Upcoming Nineteenth Production |
| We can definitely use the same protective order stamp for this production. Thanks, |
| M, please let me know what you prefer for stamping the JPMC returns. I’m happy to coordinate! |
| Thanks, |
| From: |
Sent: Wednesday, August 4, 2021 9:56 AM¶
| To: Cc: Drescher, Sunny (USANYS) [Contractor] < >; Bohrer, William (USANYS) [Contractor] Subject: RE: Upcoming Nineteenth Production |
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| Thanks |
| I’m going to defer to on how to stamp the JPMC returns. |
| My preference would be to use the same stamp we used in our most recent productions, but please let me know if that label is too long to be workable, in which case we’ll figure out an alternative. |
| From: |
| Sent: Wednesday, August 4, 2021 9:53 AM |
| >; To: |
Subject: Upcoming Nineteenth Production¶
Hi all,¶
Cc¶
has finished pulling the FBI Recovered Metadata from the shared, so we will be able to stamp those materials soon. They are 217 GB in size, so we should ask defense counsel for a 500GB drive for us to load the entire Nineteenth Production onto. In the meantime, I had a couple questions regarding the remaining materials in the pending production:¶
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- How would you like us to stamp the materials so that they comply with the correct protective order designation? We can use “SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17,” as we did in the most recent 3500 production, but I wanted to confirm with you all first.
I’m happy to chat further if anything’s unclear. Thanks very much, all!¶
Paralegal Specialist U.S. Attorney’s Office SDNY 1 St. Andrew’s Plaza New York, NY 10007¶