From: "=II, (USANYS)" To: ' Cc: Subject: [EXTERNAL EMAIL] - ENV: US v. Maxwell - [conferral re photo and other discovery deficiencies] Date: Fri, 23 Apr 2021 15:50:27 +0000 Importance: Normal Attachments: Problem Bates Numbers_ in_ Client Production.pdf Hi As you can see below, Maxwell's attorneys have asked to be provided copies of the images from the Highly Confidential drives because they claim they are unduly burdensome to review and all contain adult nudity. Would you please give me a call to discuss when you have a moment? Thanks, From: Laura Menninger < Sent: Wednesday, April 21, 2021 1:42 PM To: Cc: > > Subject: US v. Maxwell - [conferral re photo and other discovery deficiencies] I'm writing to follow-up on our discussion last Thursday regarding the photo evidence and to address a number of other critical problems with the discovery provided to date. Unfortunately, both in the production to defense counsel and on the hard-drive supplied by your office to our client at MDC, there are thousands, if not hundreds of thousands, of photos that are still unreadable. We have spent countless hours, and a chunk of our client's resources, trying to rectify a number of these problems ourselves, to no avail. Our ability, and our client's ability, to review all of the discovery in this case is absolutely critical and is constitutionally guaranteed. Unless you can quickly propose a solution, we believe we need to raise this with the Court. • We do not have a functional copy the Excel spreadsheet located at SDNY_GM_00467566. I have confirmed that the original spreadsheet provided to us is corrupt and the vendor and e-discovery provider cannot open it. • The other two Excel spreadsheets from the production (and presumably the one we cannot open) are insufficiently detailed to tell us which photo goes with which meta-data. o The index contains multiple instances of the same "file name" with different hash values. o The index does not match an