EFTA00084054.pdf

From: (USANYS)" To: la >, " Subject: FW: Hard Drives Date: Wed, 29 Sep 2021 18:59:04 +0000 Importance: Normal Embedded: Re:_Maxwell drive delivery_Monday_t_II.msg; RE:_Drive delivery_to_MDC on Monday_1_11.insg Inline-Images: image001.gif; image002.jpg Proposed response. Please feel free to edit content and tone. Mpreviously delivered a drive to the MDC in January (emails attached on this). Our paralegals received the hard drive yesterday. It has been loaded with the discovery and is being sent out today. As for the materials due on October 11, the materials for you and your co-counsel will be available for pickup on that date or will otherwise be mailed out; please let us know what you prefer. My understanding of your below emails is that you are requesting that we arrange an in-person meeting between your client and an agent at the MDC for personal hand delivery of a hard drive on Monday, which is a federal holiday. If you would like, please send us two hard drives for Ms. Maxwell. We will plan to send one of the hard drives by mail on Monday. We cannot guarantee that we will be able to have an agent personally hand deliver the hard drive, but we will try to have an agent deliver the hard drive to counsel or a designated person at the MDC on Tuesday. Best, From: Christian Everdell Sent: Wednesday, September 29, 2021 11:00 AM To: (USANYS) Cc: Laura Menninger < >; Thomas J. Powers Subject: [EXTERNAL] RE: Hard Drives ) < >; Jeff Pagliuca - As a follow-up to this, we spoke tc at the MDC.Minformed us that if we want Ms. Maxwell to receive the hard drive on the same day that it is produced, it will have to be hand-delivered to Ms. Maxwell in the visiting room by one of the agents. Can you please make arrangements for that to happen? Happy to discuss if you like. Thanks, Chris From: Christian Everdell Sent: Tuesday, September 28, 2021 10:14 PM To: (USANYS)' Cc: Jeff Pagliuca EFTA00084054 >; Laura Menninger <I >; Thomas J. Powers Subject: RE: Hard Drives Ms. Maxwell has still not received the disk or the hard drive. Can I ask you to follow-up with MDC about this? Also, we are in the process of obtaining several 64GB hard drives, which we will deliver to 1 STA shortly. As we discussed, we will expect to receive all the materials that are due on Oct. 11 on the day of the deadline. That includes the 3500 material, Giglio material, 404(b) notice and evidence, co-conspirator identities and statements, the government's witness list, and the government's exhibit list. We will also expect Ms. Maxwell to receive those materials on the same day. Given the likely volume and importance of these materials, and the closeness of the trial date, we cannot accept any delays or other snafus that typically happen in getting Ms. Maxwell her copy of the discovery in the MDC. Please let me know if you would like to discuss logistics. We would like this to be as smooth as possible. Thanks, Chris From: (USANYS) Sent: Friday, September 24, 2021 7:19 PM To: Christian Everdell c= > Cc: Jeff Pagliuca >; Laura Menninger < >; Thomas J. Powers Subject: RE: Hard Drives Chris, We have not yet received the hard drive, but we will let you know when receive it and will load it with the 9/13 production to send to Ms. Maxwell. As for the disk, we just learned yesterday that the MDC returned the disk to us. We made another copy and are mailing that to your client today. As for the size of the hard drive for 3500 materials, we think a drive of 64GB should work. We will let you know if that changes. As for the Touhy request, we are in the process of getting in touch with the individuals you identified in your letter to confirm their availability and discuss logistics. We have spoken with a number of them and will let you know when that is complete. With respect to the substance, we anticipate addressing that in our motions in limine. Best, From: Christian Everdell Sent: Friday, September 24, 2021 6:05 PM To: Cc: Laura Menninger Subject: (EXTERNAL) RE: Hard Drives )< >; >; : Thomas J. Powers (USANYS) < >; Jeff Pagliuca EFTA00084055 All — As a follow-up to this, I have been informed that the MDC apparently (and inexplicably) sent the disk back to SDNY. Can you please expedite another copy of the disk to Ms. Maxwell at the MDC? And I would also ask you to call Ms. Papapetru before sending it so that she is aware that it is coming so we avoid this problem. Thanks, Chris From: Christian Everdell Sent: Friday, September 24, 2021 10:39 AM To: (USANYS)' Cc: >; Laura Menninger < ; Thomas J. Powers Jeff Pagliuca Subject: Hard Drives M, El and I am emailing about a few items. First, we realized we never sent you a hard drive for the most recent 9/13 production to send to Ms. Maxwell. We sent it to 1 STA yesterday to attention. Can you confirm receipt? And I don't think she has received the disk you sent. Can you confirm that it was sent to MDC? Second, we wanted to return to you about the size of the hard drives we will need to get you for the production of 3500 material. As we mentioned on our last call, we want to be able to receive the loaded hard drives on the day of the deadline on Oct. 11, so we would like to deliver the drives to you early so that they can be loaded ahead of time. You told us on the last call to contact you this week so that you could advise us on the size of the drives. Can you tell us how big the drives need to be? Third, can you tell us the status of the Touhy request we made on August 30? Thanks, Chris Christian R Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 I view bio www.cohengresser.com New York I Paris I Washington DC I London 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. If 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. EFTA00084056 PRIVACY: A complete copy of our privacy policy can be viewed at https://Www.coheneressercom/privacrpolicx EFTA00084057