From: " ci To: Christian Everdell " (USANYS)" Cc: "Mark S. Cohen" Bobbi Stemheim Jeff Pagliuca •, "'Laura Henninger"' Subject: RE: Discovery Requests Date: Mon, 18 Jan 2021 03:04:48 +0000 Inline-Images: image001.jpg; image002.jpg Chris, Below please find our responses. 1. As we have recently discussed, Ms. Maxwell now has access to the 4TB drive containing a full set of the discovery produced to date. It took a significant amount of time to create this copy due to the volume of discovery and delays on the part of our vendor, who assisted in creating the copy. 2. As we have recently discussed, Ms. Maxwell now has a drive containing the contents of the CD produced on November 18, 2020. 3. As I conveyed to you over the phone and in a recent email, the materials produced from the Subject Devices all contain metadata indicating the "NYC" CART Evidence Number of the device from which each document was extracted. In our November 18, 2020 discovery letter, we provided you with a chart setting forth which "NYC" CART Evidence Number corresponds with which Subject Device in our warrants. If you still need a detailed index of all 1.2 million documents with the specific Subject Device indicated, please let me know, and I will ask one of our paralegals to compile one. 4. We produced the FBI report bearing Bates number SDNY_GM_02050812-14 in the form in which it was recovered from one of Epstein's devices. In other words, we did not apply any redactions to that document; rather, the redactions existed on the document at the time the document was found during the FBI's search of Epstein's devices. We are not aware of any legal basis for your request for a log of redactions. If you have any legal authority on that point, we would be happy to consider it. As a courtesy, I will note that our office did not apply redactions to any material that was identified responsive during the searches of Epstein's devices. 5. We are aware of our discovery obli