Fron: ee ee Subject: RE: Discovery Issues Date: Thu, 29 Oct 2020 19:54:37 +0000 Attachments: 2020.10.29 MDC_-_Maxwell_ PASSWORD.pdf Inline-Images: image001 .jpg; image002.jpg Of course — it’s attached here. Thanks! 1 Sent: Thursday, October 29, 2020 3:53 PM a ee Subject: RE: Discovery Issues Thank you! Would you please send me the password letter so that | can send it to MDC counsel? +o Sent: Thursday, October 29, 2020 2:58 PM a ee Subject: RE: Discovery Issues The CD and the envelope containing the password have both been left with Fedex — and both will go out for MDC tonight. Thanks! Sent: Thursday, October 29, 2020 2:14 PM a a Subject: RE: Discovery Issues | just uploaded the reproduction to their FTP. The zip file is encrypted with the password USAOSdhy1!. Would you please let defense know so that they will be able to open the files is going to take care of burning the materials to a cd and sending them to MDC. Fr Sent: Thursday, October 29, 2020 1:51 PM or Cs a Subject: FW: Discovery Issues See below. Would you please produce everything except the bottom four rows to counsel via FTP and to Maxwell on a CD today? And then would you please put the items from the bottom four rows into the Sixth Production TO BE PRODUCED folder? EFTA00076276

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Thanks, a From: Christian Everdell Sent: Thursday, October 29, 2020 1:49 PM T FCCC Ce: Mark S. Cohen {is ; Jeff Pagliuc' i | ura Menninger 18.088) C STERNHE|' Thomas J. Powers i Subject: RE: Discovery Issues Thanks for the response Why don’t you produce everything but the last four rows on the FTP site. Then whenever you make your next production, you can include those on the drive we give you. Thanks, Chris From: Sent: Thursday, October 29, 2020 10:55 AM To; Cc: Mark S. Cohen; ‘Jeff Pagliuca'; Laura Menninger; ‘BOBBI C STERNHEIM’ Subject: RE: Discovery Issues Chris, Below please find responses to the discovery issues you raised: 1. The following table addresses the gaps you identified in bates numbering. Please let us know if you would like us to reproduce the ranges in the bottom four rows, which were already included in two prior productions and will require another drive to reproduce, or if you have been able to locate those ranges, in which case we can produce the remaining ranges via the FTP site: ProdBegBates ProdEndBates ap due to technical error in loading prior production; the document will be sow cw 00006305 | sony cm_ 00006305 _fneudedina replacement producton. | SDNY_GM_00006305 SDNY_GM_00006305 ncluded in a replacement production. sony_ow_00006307 | soy cm_ 00006307 _fneudedin replacement progucton | SDNY_GM_00006307 SDNY_GM_00006307 ncluded in a replacement production. ap due to technical error in loading prior production; the document will be ap due to technical error in loading prior production; the document will be ap due to technical error in loading prior production; the document will be ncluded in a replacement production. sony cm_o0006315 | son cw_o0006s:5 _frduded na replacement productions | SDNY_GM_00006315 SDNY_GM_00006315 ncluded in a replacement production. ap due to technical error in loading prior production; the document will be SDNY_GM_00006317 SDNY_GM_00006317 ncluded in a replacement production. ap due to technical error in loading prior production; the document will be SDNY_GM_00006330 SDNY_GM_00006330 ncluded in a replacement production. ap due to technical error in loading prior production; the document will be ncluded in a replacement production. | sowy am_ 00006334 | sonv_cw_oon0s334 _frduded ina replacement production | SDNY_GM_00006334 SDNY_GM_00006334 ncluded in a replacement production. ap due to technical error in loading prior production; the document will be sonv_cw_coo06338 | sow cm 00006338 _fnededinareplacementproauctons "| SDNY_GM_00006338 SDNY_GM_00006338 ncluded in a replacement production. ap due to technical error in loading prior production; the document will be ncluded in a replacement production. EFTA00076277

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ap due to technical error in loading prior production; the document will be SDNY_GM_00086253 SDNY_GM_00086289 ncluded in a replacement production. Produced on August 21, 2020 and reproduced on September 3, 2020. We will eproduce these as a courtesy; however, doing so would mean that an FTP site SDNY_GM_00167911 SDNY_GM_00168477 ould not be feasible for sharing the documents. Produced on August 21, 2020 and reproduced on September 3, 2020. We will eproduce these as a courtesy; however, doing so would mean that an FTP site SDNY_GM_00168488 SDNY_GM_00169165 ould not be feasible for sharing the documents. Produced on August 21, 2020 and reproduced on September 3, 2020. We will eproduce these as a courtesy; dada doing so would mean that an FTP site SDNY_GM_00169184 SDNY_GM_00169491 i i . Produced on August 21, 2020 and reproduced on September 3, 2020. We wi eproduce these as a courtesy; however, doing so would mean that an FTP site SDNY_GM_00169505 SDNY_GM_00169735 ould not be feasible for sharing the documents. 2. The file bearing the bates number SDNY_GM_00007581 is an .exe file. This is the application through which the documents from PayPal (SDNY_GM_00007426 - SDNY_GM_00007580) were retrieved. The .exe file itself does not contain any information. 3. Thank you for identifying the clerical errors in the bates numbers from the 10/2 production. The relevant portions of the “GM Documents” are now stamped with the range “SDNY_GM_00323935-324015.090.” We will provide you with re- stamped versions in a new production. 4. Weill produce new versions of the .tif files you identified in a new production. They have each been checked manually to ensure that they open and are viewable. 5. As mentioned above, we can make this new production over the FTP site if you do not require copies of the ranges in the bottom four rows of the above table. Please let us know whether you would like us to omit those ranges and use the FTP site, or include those ranges and make a production on a drive. 6. We will produce a copy of this production to Ms. Maxwell at the MDC. If you require a reproduction of the ranges in the bottom four rows of the above table, this production will need to be on a drive. If you do not need those ranges to be included, then this production can be made on a CD. Best, Assistant United States Attorney Southern District of New York 1 St. Andrew’s Plaza New York, NY 10007 Fo Sent: Wednesday, October 28, 2020 12:11 PM To: Christian verde! ll Ce: Mark S. Cohen < ; Jeff Pagliuca’ -F —Tti<“‘i‘;;””*”*;*~C*@S Laura Menninger (2088! ¢ STERNHEIV: Subject: RE: Discovery Issues Chris, Thank you for bringing these issues to our attention. We will discuss internally and will get back to you as soon as possible to address these concerns. EFTA00076278

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Best, Zz PS Assistant United States Attorney Southern District of New York 1 St. Andrew's Plaza New York, NY 10007 From: Christian Everdell Po Sent: Tuesday, October 27, 2020 10:35 PM Te Ce: Mark S. Cohen < i ; Jeff Pagliuca' i: Laura Menninger Subject: Discovery Issues lam writing to alert you to some additional discovery issues from the prior productions that we'd like to clear up. These issues apply to the productions to both defense counsel and to Ms. Maxwell. 1. Bates numbering gaps from the first three productions (8/5, 8/13, and 8/21). The table at the end of the email lists bates numbering gaps in these production volumes. Please provide the missing documents or affirm these are intentional gaps in the numbering. 2. There is one password protected zip file in the 8/5 production bearing the bates number SDNY_GM_00007581. Please provide the password for this file. 3. In the 10/2 production, there are overlapping bates numbers + SDNY_GM_00323935-324015 (GM Documents) actually ends at 3249105, not 324005 « This resulted in overlapping bates numbers with the two folders below. We suggest renumbering GM documents numbered 324016 — 324105 as SONY_GM_00324015.001, .002, etc. >» SDNY_GM_00324016-324036 (Citibank) >» SDNY_GM_00324037-325754 (UBS) 4. In the 10/2 production, the following *.tif files are corrupt and will need to be replaced « SDNY_GM_00243326.tif + SDNY_GM_002435839.tif « SDNY_GM_00243976.tif + SDNY_GM_00244145.tif « SDNY_GM_00244151.tif « SDNY_GM_00244375.tif + SDNY_GM_00244385.tif « SDNY_GM_00244520.tif « SDNY_GM_00245161.tif « SDNY_GM_00245170.tif « SDNY_GM_00245171.tif « SDONY_GM_00245206.tif 5S. Given the relatively small volume of replacements, we suggest sending the corrected documents to defense counsel using our FTP site in an encrypted zip file using the link below. + https://cohengr rsharefile.com/r-r3352cOcf22a4b2: EFTA00076279

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6. The corrected documents will have to be sent separately to Ms. Maxwell in the MDC. Bates Gaps from the 8/5, 8/13 and 8/21 productions: SDNY_GM_00006338 | SDNY_GM_00006338 SDNY_GM_00086253 | SDNY_GM_00086289 SDNY_GM_00169184 | SDNY_GM_00169491 SDNY_GM_00169505 | SDNY_GM_00169735 Thanks, Chris Christian R Everdell COHEN & GRESSER LLP it httos://maw, cohengresser.com/pnvacy-paticy, EFTA00076280