From: "SI" 'ale To: (USANYS) [Contractor)" alMIIM> Cc: ' (USANYS)" Subject: FW: Discovery Issues Date: Mon, 29 Mar 2021 18:59:01 +0000 Attachments: SDNY_Production_Issues_2O21O329.xlsx; SlipsheetExample-SDNY_GM_00541380.pdf Inline-Images: image002.jpg; image004.jpg Hi[, We just received the below and attached regarding discovery in the Maxwell case. Many of these questions relate to productions that PAE prepared. Would you please take a look and let me know when would be a good time this week for a call to discuss? Thanks, From: Christian Everdell ‹ > Sent: Monday, March 29, 2021 2:40 PM To: ) c >; >"; (USANYS) Cc: 'Jeff Pagliuca' < >; Laura Menninger Bobbi Sternheim ) Subject: Discovery Issues and M — We write to raise a few issues concerning the discovery. Below is the list of items. Please let me know if you are free for a call to discuss. 1. On our last call, we asked you if we could send our client a hard drive containing the discovery that we had created (without the highly confidential items). You had said you would check to see if you could facilitate this. We have not heard back from you. Are you able to send Ms. Maxwell the hard drive? 2. The last two productions you sent to Ms. Maxwell on disks. As you know, she cannot read disks on her laptop and must use the prison computer. But the prison computer cannot read some of the files. We can include these files on our hard drive to send to Ms. Maxwell. Otherwise, you will need to produce them on a hard drive. Please advise which way you would like to proceed. 3. A number of the emails in the discovery— over 109,000 — were produced without their attachments (see tab 1 of the attached Excel file). Instead, the attachments appear as slip-sheets (see example attached). Please provide the missing attachments, if they exist. 4. A number of electronic documents — over 110,000 —that were extracted from one of Epstein's devices, as identified by a CART number, have metadata that ind