Subject: RE: Discovery Issues

From: Cc: Subject: RE: Discovery Issues Date: Thu, 29 Oct 2020 19:54:37 +0000 Attachments: 2020.10.29_MDC_-_Maxwell_PASSWORD.pdf Inline-Images: image001.jpg; image002.jpg Of course — it's attached here. Thanks! From Sent: Thursday, October 29, 2020 3:53 PM To: Subject: RE: Discovery Issues Thank youl Would you please send me the password letter so that I can send it to MDC counsel? From' Sent: Thursday, October 29, 2020 2:58 PM To: Subject: RE: Discovery Issues The CD and the envelope containing the password have both been left with Fedex — and both will go out for MDC tonight. Thanks! From: Rohrer Sent: Thursday, October 29, 2020 2:14 PM To: Subject: RE: Discovery Issues I just uploaded the reproduction to their FTP. The zip file is encrypted with the password USAOsdnyll. Would you please let defense know so that they will be able to open the files?Mis going to take care of burning the materials to a cd and sending them to MDC. From Sent: Thursday, October 29, 2020 1:51 PM To Cc: Subject: FW: Discovery Issues See below. Would you please produce everything except the bottom four rows to counsel via FTP and to Maxwell on a CD today? And then would you please put the items from the bottom four rows into the Sixth Production TO BE PRODUCED folder? EFTA00076276 Thanks, From: Christian Everdell Sent: Thursday, October 29, 2020 1:49 PM Cc: Mark S. Cohen a; 'Jeff Pagliuca' 'BOBBI C STERNHEIM' Subject: RE: Discovery Issues Laura Menninger ; Thomas J. Powers Thanks for the response Why don't you produce everything but the last four rows on the FTP site. Then whenever you make your next production, you can include those on the drive we give you. Thanks, Chris From: Sent: Thursday, October 29, 2020 10:55 AM To: Cc: Mark S. Cohen; 'Jeff Pagliuca'; Laura Menninger; 'BOBBI C STERNHEIM' Subject: RE: Discovery Issues Chris, Below please find responses to the discovery issues you raised: 1. The following table addresses the gaps you identified in bates numbering. Please let us know if you would like us to reproduce the ranges in the bottom four rows, which were already included in two prior productions and will require another drive to reproduce, or if you have been able to locate those ranges, in which case we can produce the remaining ranges via the FTP site: ProdBegBates ProdEndBates SDNY_GM_00006303 SDNY_GM_00006303 Gap due to technical error in loading prior production; the document will be included in a replacement production. SDNY_GM_0000630S SDNY_GM_00006305 Gap due to technical error in loading prior production; the document will be included in a replacement production. SDNY_GM_00006307 SDNY_GM_00006307 Gap due to technical error in loading prior production; the document will be included in a replacement production. SDNY_GM_00006309 SDNY_GM_00006309 Gap due to technical error in loading prior production; the document will be included in a replacement production. SDNY_GM_00006311 SDNY_GM_00006311 Gap due to technical error in loading prior production; the document will be included in a replacement production. SDNY_GM_00006313 SDNY_GM_00006313 Gap due to technical error in loading prior production; the document will be included in a replacement production. SDNY_GM_00006315 SDNY_GM_00006315 Gap due to technical error in loading prior production; the document will be included in a replacement production. SDNY_GM_00006317 SDNY_GM_00006317 Gap due to technical error in loading prior production; the document will be included in a replacement production. SDNY_GM_00006330 'Gap SDNY_GM_00006330 due to technical error in loading prior production; the document will be included in a replacement production. SDNY_GM=00006332 SDNY_GM _00006332 Gap due to technical error in loading prior production; the document will be included in a replacement production. SDNY_GM_00006334 SDNY_GM_00006334 Gap due to technical error in loading prior production; the document will be included in a replacement production. SDNY_GM_00006336 SDNY_GM_00006336 Gap due to technical error in loading prior production; the document will be included in a replacement production. SDNY_GM_00006338 'Gap SDNY_GM_00006338 due to technical error in loading prior production; the document will be included in a replacement production. SDNY_GM_00006340 SDNY_GM_00006340 Gap due to technical error in loading prior production; the document will be included in a replacement production. EFTA00076277 SDNY_GM_00086253 SDNY_GM_00086289 Gap due to technical error in loading prior production; the document will be included in a replacement production. SDNY_GM_00167911 SDNY_GM_00168477 Produced on August 21, 2020 and reproduced on September 3, 2020. We will reproduce these as a courtesy; however, doing so would mean that an FTP site would not be feasible for sharing the documents. SDNY_GM_00168488 SDNY_GM_00169165 Produced on August 21, 2020 and reproduced on September 3, 2020. We will reproduce these as a courtesy; however, doing so would mean that an FTP site would not be feasible for sharing the documents. SDNY GM 00169184 SDNY GM 00169491 Produced on August 21, 2020 and reproduced on September 3, 2020. We will reproduce these as a courtesy; however, doing so would mean that an FTP site would not be feasible for sharing the documents. SDNY_GM_00169505 SDNY_GM_00169735 Produced on August 21, 2020 and reproduced on September 3, 2020. We will reproduce these as a courtesy; however, doing so would mean that an FTP site would not be feasible for sharing the documents. 2. The file bearing the bates number SDNY_GM_00007581 is an .exe file. This is the application through which the documents from PayPal (SDNY_GM_00007426 - SDNY_GM_00007580) were retrieved. The .exe file itself does not contain any information. 3. Thank you for identifying the clerical errors in the bates numbers from the 10/2 production. The relevant portions of the "GM Documents" are now stamped with the range "SDNY_GM_00323935-324015.0907 We will provide you with re- stamped versions in a new production. 4. We will produce new versions of the .tif files you identified in a new production. They have each been checked manually to ensure that they open and are viewable. 5. As mentioned above, we can make this new production over the FTP site if you do not require copies of the ranges in the bottom four rows of the above table. Please let us know whether you would like us to omit those ranges and use the FTP site, or include those ranges and make a production on a drive. 6. We will produce a copy of this production to Ms. Maxwell at the MDC. If you require a reproduction of the ranges in the bottom four rows of the above table, this production will need to be on a drive. If you do not need those ranges to be included, then this production can be made on a CD. Best, Assistant United States Attorney Southern District of New York 1 St. Andrew's Plaza Ncw York, NY 10007 From• Sent: Wednesday, October 28, 2020 12:11 PM To: Christian Everdell Cc: Mark S. Cohen < ; 'Jeff Pagliuca' ; 'BOBB1C STERNHEIM' Subject: RE: Discovery Issues Chris, ; Laura Menninger Thank you for bringing these issues to our attention. We will discuss internally and will get back to you as soon as possible to address these concerns. EFTA00076278 Best, Assistant United States Attorney Southcm District of New York I St. Andrew's Plaza New York, NY 10007 From: Christian Everdell Sent: Tuesday, October 27, 202010:35 PM Tol Cc: Mark S. Cohen <a 'Jeff Pagliuca' Laura Menninger 'BOBER C STERNHEIM' Subject: Discovery Issues I am writing to alert you to some additional discovery issues from the prior productions that we'd like to clear up. These issues apply to the productions to both defense counsel and to Ms. Maxwell. 1. Bates numbering gaps from the first three productions (8/5, 8/13, and 8/21). The table at the end of the email lists bates numbering gaps in these production volumes. Please provide the missing documents or affirm these are intentional gaps in the numbering. 2. There is one password protected zip file in the 8/5 production bearing the bates number SDNY_GM_00007581. Please provide the password for this file. 3. In the 10/2 production, there are overlapping bates numbers • SDNY_GM_00323935-324015 (GM Documents) actually ends at 324105, not 324015 • This resulted in overlapping bates numbers with the two folders below. We suggest renumbering GM documents numbered 324016— 324105 as SDNY_GM_00324015.001, .002, etc. SDNY_GM_00324016-324036 (Citibank) '.-SDNY_GM_00324037-325754 (OBS) 4. In the 10/2 production, the following •.tif files are corrupt and will need to be replaced • SDNY_GM_00243326.tif • SDNY_GM_00243589.tif • SDNY_GM_00243976.tif • SDNY_GM_00244145.tif • SDNY_GM_00244151.tif • SDNY_GM_00244375.tif • SDNY_GM_00244385.tif • SDNY_GM_00244520.tif • SDNY_GM_00245161.tif • SDNY_GM_00245170.tif • SDNY_GM_00245171.tif • SDNY_GM_00245206.tif 5. Given the relatively small volume of replacements, we suggest sending the corrected documents to defense counsel using our FTP site in an encrypted zip file using the link below. • hips://rohengressersharefile comir-r11S7r0/177a4Orlf{ EFTA00076279 6. The corrected documents will have to be sent separately to Ms. Maxwell in the MDC. Bates Gaps from the 8/5, 8/13 and 8/21 productions; ProdBegBates P rod E nd Bates SDNY_GM_00006303 SDNY_GM_00006303 SDNY_GM_00006305 SDNY_GM_00006305 SONV_GM_00006307 SDNY_GM_00006307 SDNV_GM_00006309 SDNY_GM_00006309 SDNY_GM_00006311 SDNY_GM_00006311 SDNY_GM_00006313 SDNY_GM_00006313 SDNY_GM_00006315 SDNY_GM_00006315 SDNY_GM_00006317 SDNY_GM_00006317 SONV_GM_00006330 SDNY_GM_00006330 SONV_GM_00006332 SDNY_GM_00006332 SONV_GM_00006334 SDNY_GM_00006334 SDNY_GM_00006336 SDNY_GM_00006336 SDNY_GM_00006338 SDNY_GM_00006338 SDNY_GM_00006340 SDNY_GM_00006340 SONV_GM_000862S3 SDNY_GM_00086289 SONV_GM_00167911 SDNY_GM_00168477 SONV_GM_00168488 SDNY_GM_00169165 SDNY_GM_00169184 SDNY_GM_00169491 SDNY_GM_0016950S SDNY_GM_00169735 Thanks, Chris Christian R Everdell COHEN & GRESSER LLP 600 Thtrd AVeLL , New York. NY 10C L_ view bio yNNe cohericiresser corn New York I Paris I Washington DC I London CONFIDENTIALITY NOTICE: The information contained in this 0-Mad may be confidential andlor privileged. 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