From: To: Laura Mennin er Cc: Jeff Pagliuca It 'Bobbi Stemhet Subject: RE: US v. Maxwell - [conferral re photo and other discovery deficiencies] Date: Wed, 12 May 2021 03:15:02 +0000 Laura, I have consulted with the FBI and our vendor regarding the issues you raised with the overlay. Below is what I understand from them: • When using the overlay, you should require only a match of the hash value. • When our vendor uses the overlay, they do not see any production numbers that do not have a match in the index. If you are still seeing outliers, please let us know which files are not matching up with the index, and our vendor will look into what that issue could be. • The 17 files with no hash values were either incomplete files or corrupt files when they were recovered from the CDs. We produced them to you so that you would have a copy of every file on the CDs that did not have identifiable nudity. • Any non-unique hash values are duplicate files. There were many duplicate files on the CDs. The FBI and vendor did not de-duplicate the images before producing them in an effort to ensure that you had a complete set of all files recovered from the CDs. • There are a number of files that were recovered from the CDs but are unopenable on our end. We produced them to you so that you would have a copy of every file on the CDs that did not have identifiable nudity. If you would like to check to see if any particular files are unopenable on our end, we would be happy to check. Given the above, the FBI and the vendor believe the overlay previously provided should be sufficient to allow you to review the metadata in this production. k o est Assistant United States Attorney Southern District of New York 1 St. Plaza New York, NY 10007 From: Laura Menninger Sent: Wednesday, April 2 , : To: <a < (USANYS) Cc: Jeff Pagliuc 'Bobbi EFTA00068453