Subject: RE: US v. Maxwell - [conferral re photo and other discovery deficiencies] Date: Wed, 28 Apr 2021 03:34:35 +0000 Attachments: SDNY_PROD011_-_Overlay.zip ## Laura, Attached please find a metadata overlay for the production of images from the CDs recovered from Epstein’s residence. This file contains the file name and the MDF Hash for each file, which corresponds with the information contained in the SDNY_GM_00467567 Spreadsheet. This overlay should allow your team to see which row of metadata corresponds with which Bates number in the production. Subject: RE: US v. Maxwell - [conferral re photo and other discovery deficiencies] Laura, Our vendor has explained the issue with SDNY_GM_00467566. That file is a temporary file without content. The file that contains the content is SDNY_GM_00467567. Best, EFTA00081420 Assistant United States Attorney Southern District of New York 1 St. Andrew's Plaza New York, NY 10007 Subject: RE: US v. Maxwell - [conferral re photo and other discovery deficiencies] ## Laura, I am working with our team as quickly as we can to address the issues you raised in the below email. In particular: - I have asked our vendor to look into the issues with SDNY_GM_00467566. When I attempt to access that document on our Relativity database, I also receive an error message saying that the document is corrupt. I am not sure what this spreadsheet is because the only two spreadsheets that I’m aware of that correspond with the SDNY_PROD011 contained in the November 9, 2020 production are the two other Excel spreadsheets you referenced. In any event, I am looking into the issue. - I am similarly working with our vendor to understand how to best identify for you which Bates number corresponds with the metadata in the index contained in the Excel spreadsheets. - Can you please provide me with a list of the photos that you are unable to view? Once I have that list, I will check to see whether we are able to open them on our end. - Can you be more specific in identifying photographs that you believe should have been produced but have been omitted, please? We have endeavored with the FBI to produce copies of all non-nude photographs recovered from searches of Epstein’s residence to the defense, and I am not aware of any intentional omissions. - I am discussing with the FBI your request that we produce all Highly Confidential images to you. I will respond to that request next week. - Once we have a firm trial date, I will let you know by what date I expect to be able to provide you with a list of the Highly Confidential photographs we may introduce at trial. - I am working with our paralegals to assess the list of files that your client is unable to review at the MDC. As soon as we have finished looking into those issues, I will let you know. Best, From: Laura Menninger· **Sent:** Wednesday, April 21, 2021 1:42 PM To: