Subject: RE: Discovery Requests

Date: Fri, 29 Jan 2021 14:48:14 +0000



Inline-Images: image001.jpg; image002.jpg



We just need to send the materials to defense via their FTP.

## From:|

**Sent:** Friday, January 29, 2021 9:42 AM

Subject: RE: Discovery Requests

This completes request number 6 that defense made. There were a number of other requests that defense made beyond number 6 but we only addressed that one specifically. Please let us know if we should be working on any of the other requests that defense made.

## From:

**Sent:** Thursday, January 28, 2021 5:51 PM



Subject: RE: Discovery Requests

Thanks so much! To confirm, does this complete everything that the defense asked us for?

## From:

Sent: Wednesday, January 27, 2021 12:14 PM



Subject: RE: Discovery Requests

The two cover letters heading to MDC today with the disc are attached. Thanks, all!

## From:

**Sent:** Wednesday, January 27, 2021 9:56 AM

## Subject: RE: Discovery Requests

Hi all - I just checked PROD011 and it contains all the requisite ranges. I’ll go ahead and burn a CD for MDC containing the PROD011 and PROD015 .dat files and the re-bates stamped items, and I’ll have that sent out today. Thanks!

## From:

**Sent:** Wednesday, January 27, 2021 9:37 AM

To: ) <

## Subject: RE: Discovery Requests

We have all of the materials just about prepared to go out. is doing a last check of the PROD011 that exported to the shared and then everything will be all set.

**Sent:** Thursday, January 21, 2021 9:40 PM

EFTA00102000

## Cc:

Subject: RE: Discovery Requests

Thanks so much, and my apologies for the delayed response. I’ve been traveling for work and fell behind on emails as a result. I will email defense counsel to ask them to send a link where they’d like the materials uploaded.

## From:



Sent: Wednesday, January 20, 2021 10:29 AM





## Subject: RE: Discovery Requests

I can upload these files for defense counsel today and will be able to load a disc for Maxwell when I’m back at the office tomorrow. I recall that the last time we produced to defense in this manner they preferred to use their FTP site. Would you mind asking them to send over a link to where they’d like the materials uploaded? Thanks!

## From:

**Sent:** Tuesday, January 19, 2021 8:27 PM



Subject: RE: Discovery Requests

Thanks so much! Once you have the renumbered files, would you please prepare them for production to the defense? Ideally, they could go on a disc for Maxwell and USAfx for defense counsel, but let me know if it’s too large.



## Subject: RE: Discovery Requests

The materials from 6a have been re-stamped with the range: SDNY_GM_00327069.001 – SDNY_GM_00327069.794. They are currently being loaded here:

Once we have 6b and 6c sorted out we will let you know.

**Sent:** Tuesday, January 19, 2021 10:21 AM

Subject: RE: Discovery Requests

We will take care of 6a today.

6b and 6c will require us to check the drives that we have at the office. Neither nor I will be at the office today or tomorrow. I plan on going in on Thursday and will be able to check on those issues that defense points out. Not to jump to conclusions but I believe that PAE’s .DAT files typically include only the beginning number in a range which would give the appearance of gaps in the production. As such there is a decent chance that defense is incorrect about the gaps as they list them although we will not know until we actually check the productions.

Thanks,





Subject: FW: Discovery Requests

Would you please take a look at request number 6 below and figure out how to address it? I believe you may need to work with for some of these issues.

Thanks,