EFTA00080617.pdf

From: Christian Everdell To: " " (USANYS)" Cc: Bobbi Stemheirn Subject: Discovery Laptop Access Date: Wed, 13 Jan 2021 06:05:35 +0000 Embedded: Discovery_Requests.msg Inline-Images: image001.jpg; image002.jpg I write to again request that Ms. Maxwell be given access to the laptop computer on the weekends. She recently informed us that the prison computer can't read a substantial portion of the materials on the hard drives. This means that she effectively loses the entire weekend to review her discovery. If she was able to have access to the laptop on the weekends when she was in quarantine, I don't see why she cannot have it now. Also, Ms. Maxwell still has not received the 4TB hard drive with the complete production or the smaller hard drive with the materials that were originally produced on the CD. Can you please let me know when they will be provided to her? Finally, we renew our discovery requests set forth in our 1/7/2021 email (see attached). In particular, we would like to receive as soon as possible the list of Subject Devices in request #3. When can we expect to receive that? Regards, Chris Christian R Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 www.cohengresser.com New York I Paris I Washington DC I London I view bio CONFIDENTIALITY NOTICE: The information contained in this e-mail may be confidential and/or privileged. This e-mail is intended to be reviewed initially by only the individual named above. II the reader of this e-mail is not the intended recipient or a representative of the intended recipient. you are hereby notified that any review. dissemination or copying of this e-mail or the information contained herein is prohibited. If you have received this e-mail in error. please immediately notify the sender by telephone and permanently delete this e-mail. Thank you. PRIVACY: A complete copy of our privacy policy can be viewed al: MoslAvww.cohenoresser.com/privacwolicx EFTA00080617