EFTA00030926

Inline-Images: image001.jpg; image002.jpg r cI For reference, the tracking numbers are

FYI. I'm not going to be able to come into the office this week. Will someone be in and able to check the mail for this drive and get it loaded?

Our paralegals reminded me that we have produced the ranges you included in your most recent email twice: once in the third production (08-21-2020) and once in the reproduction with shortened file names (09-03-2020). We can certainly produce them a third time, but we would not be able to reproduce them again through your FTP link, as they are too large. Please provide us with a 64 GB drive if you would like us to reproduce those ranges. Best, Assistant United States Attorney

Southern District of New York

0007 212-637-2324

Thank you for sending the link. I will ask our paralegals to use it to send you the ranges you requested, including the ranges you referenced in your most recent email. Best, Assistant United States Attorney

Southern District of New York

Thanks for the follow-up. Please send the documents to the FTP link below: Also, we are missing the Bates ranges listed below. SDNY_GM_00167911 through SDNY_GM_00168477 SDNY_GM_00168488 through SDNY_GM_00169165 SDNY_GM_00169184 through SDNY_GM_00169491 SDNY_GM_00169505 through SDNY_GM_00169735 We had discussed these ranges several months ago and I believe you had agreed to reproduce them in the 11/9 production. But we do not appear to have received them. Can you send these ranges via the FTP site as well? Thanks,

Following up on this, we have now prepared all of the items you requested in point 6 below for production to you. Our paralegals have sent a copy of the materials to the MDC for your client. Would you like to provide us with an FTP link for this production, or would you like us to prepare a CD for you instead? Thanks, Assistant United States Attorney

Southern District of New York

(USANYS)

application. As you can see at Bates No. SDNY_GM_00000621, the sealing order automatically expired on December 30, 2020. Our understanding is that the District of New Hampshire unsealed the filing of its own accord in conformity with the clear language of that sealing order. Our office took no affirmative steps to unseal or otherwise release these filings. Best, Assistant United States Attorney

Southern District of New York

identifying all of the redacted documents in the discovery and the bases for each of the redactions.

5. There are a few documents that seem to be missing from the discovery. For example, the documents (SDNY_GM_00001015-3637) do not seem to include subscriber information for the various phone numbers. Also, the flight logs produced by begin at Bates number suggesting that were not produced to us. Please produce these documents to us or provide an explanation why you are not producing them to us. Please confirm whether there are other documents that were removed from the grand jury subpoena productions that we have not yet identified and the basis for their removal.

6. There are a few Bates number/metadata issues with some of the documents: a. There is an overlap between the fourth and fifth document productions. The fourth production ends at SDNY_GM_00328863, the fifth production begins at SDNY_GM_00328070. We propose renumbering the range from the fifth production (i.e., renumber SDNY_GM_00328070-328863). b. The metadata load files (*.DAT) for PROD011 had a number of gaps which are detailed in the attached Excel file. We propose that you send us a new DAT file covering only the missing documents. c. The metadata load files (*.DAT) for PROD015 had a gap from SDNY_GM_00723971 to SDNY_GM_00723981. We propose that you send us a new DAT file covering only the missing documents.

7. To the extent that the government has created an index of the documents produced on November 9 and November 18 that is more detailed than the production cover letters, we request that you provide a copy to the defense.

8. We request that the government provide copies of the grand jury subpoenas for documents issued by the government in this case. Also, please identify the date range of documents you requested in each subpoena. There is one other issue we'd like to raise. An article in the Daily Beast on Monday referenced the search warrant affidavit for the cell-site simulator used to track Ms. Maxwell's cellphone before her arrest (https://www.thedailybeast.com/how- the-fbi-tracked-down-ghislaine-maxwell-alleged-madam-of-jeffrey-epstein). The article stated that the affidavit appeared in a "newly unsealed court filing." I don't recall this affidavit being unsealed or referenced in anything that was filed on the court docket. Please confirm whether or not the government unsealed this affidavit or any other materials from the criminal discovery, and whether any discovery materials were released pursuant to FOIA requests. Regards, COHEN & GRESSER LLP Elti n I view bio www.cohengresser.com New York I Paris I Washington DC I London

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