Subject: RE: Discovery Requests¶
Date: Fri, 29 Jan 2021 14:48:14 +0000¶
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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¶
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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,¶