EFTA00074698¶
Based on the emails below, should I be available to load discovery tomorrow?¶
Thanks!¶
Subject: FW: Discovery¶
Hi all, apparently Maxwell’s firm dropped off two drives today. Did anyone receive them?¶
Tom Powers dropped off two hard drives earlier this afternoon. Please let me know if you did not receive them. Please load the complete production to date on the drive that is going to the MDC. With regard to the two drives that are already at the MDC, we want those to remain with Ms. Maxwell in the MDC for the time being.¶
As tomorrow is the deadline for the government to complete production of the initial non-electronic discovery, we expect that Ms. Maxwell will receive her drive tomorrow at MDC.¶
Regards,¶
Chris¶
Sent: Wednesday, August 19, 2020 5:54 PM¶
| Cc: | Mark S. Cohen; Jeff Pagliuca; 'Laura Menninger'; Thomas J. Powers |
| Subject: | RE: Discovery |
Chris,¶
We expect to have another discovery production ready to load by this Friday, August 21 $ ^{34} $ . This production will include the replacement files you requested as well. Would you please provide us with another drive for us to load? Our paralegal is not able to load the discovery without the McAfee encryption software, so it will be included in this production.¶
For your client’s review at MDC, if you provide us with another new drive, we can load a full set of the discovery to date (including all past productions) onto it and send it to the MDC. Once the new drive arrives at the MDC, we can request that the jail send the two prior drives back to our office. That way your client will have all of the discovery on a single drive, and we can use the older drives to send future productions to the MDC. Please let us know if that is acceptable to you.¶
Thanks,¶