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Case 1:20-cr-00330-PAE Document 753 _ Filed 08/10/22 Page 81 of 264 1507 LC7Cmax2 Flatley -— recross 1 MS. POMERANTZ: Just briefly, your Honor. 2 REDIRECT EXAMINATION 3 BY MS. POMERANTZ: 4 Q. Mr. Flatley, during the course of your review of Government 5 Exhibit 54, did you review emails? 6 A. Yes, I did. 7 Q. And as to the emails you reviewed on Government Exhibit 54, 8 how many emails did not include gmaxl@mindspring.com on the 9 email chains? 10 A. They were all from that account. 11 MS. POMERANTZ: No further questions, your Honor. 12 MS. MENNINGER: Your Honor, on that point. 13 THE COURT: Okay. 14 RECROSS EXAMINATION 15 BY MS. MENNINGER: 16 Q. You know about email clients; right? 17 A. Yes, ma'am. 18 Q. An email client is something like Outlook or Mail; correct? 19 A. Correct. 20 Q. And when an email client like Outlook or Mail is installed 21 on a computer, it often goes up to the server and refreshes 22 itself from the server whenever that computer is connected to 23 the internet; correct? 24 A. That is correct. 25 Q. Just like my cellphone may be constantly drawing down SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00018679