EFTA00098333

Subject: RE: US v. Maxwell - discovery production

Thanks very much. Was the drive addressed to me or someone else in the office? Once we track it down, we’ll be happy to load it with whatever materials you request from the prior productions.



Subject: RE: US v. Maxwell - discovery production

Thanks, . We have also just shipped another padlock drive to you, which may have already arrived. Ms. Maxwell has told us she is having some trouble opening some of the discovery she recently received. I am trying to get sense of which files she is having trouble with. Once I do, I will likely ask you to load the new padlock drive with some previously produced files.

Thanks.



Chris,

We received the drives and have finished loading them. As you requested, the padlock drive does not have McAfee encryption software and instead uses the encryption on the drive. That drive for counsel is available to be picked up at 1 St. Andrews now. The drive for Ms. Maxwell is being shipped out to the MDC via FedEx today as well.

Best,

Assistant United States Attorney Southern District of New York



From: Christian Everdell <

Sent: Friday, August 6, 2021 12:18 PM


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I should have mentioned this. To open the padlock drive, please use the info below:



Thanks,

Chris



Subject: RE: US v. Maxwell - discovery production

We are sending messenger to you shortly with one 1 TB USB drive and one 1 TB padlock drive. The USB drive is for Ms. Maxwell and the padlock drive is for counsel. We will mark them accordingly.

We have had some issues in the past with extracting information from the McAfee encryption program that you use to encrypt the data on the drives. Because the padlock drive already has onboard encryption, can you not use the McAfee encryption software on that drive? Please advise.

Thanks,

Chris



Counsel,

As I previewed in my email to yesterday, we now have set of discovery materials ready to produce to you. Attached please find the cover letter accompanying this production.

For this production, we will need two 500GB hard drives (one for counsel’s copy and one for Ms. Maxwell’s copy) on which to load the materials. If you would please address those drives to Paralegal Specialist at that will enable us to get the drives loaded more quickly.

Best,



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