EFTA00020821

From: Christian Everdell To: ' Menmn "Bobbi Stemheim Cc: ".„ 1.r" (USANYS)" Subject: RE: US v. Maxwell - Request for Extension of Discovery Deadline Date: Thu, 05 Nov 2020 22:58:30 +0000 Inline-Images: image00 I .jpg Thanks, I will speak to you then. From: [mailto Sent: Thursday, November 05, 2020 5:20 PM To: Christian Everdell; Jeff Pa liuca• Mark S. Cohen; Laura Menninger; Bobbi Stemheim Cc: ►; (USANYS) Subject: RE: US v. Maxwell - Request for Extension of Discovery Deadline Chris, Yes, we are available for a call at 9am tomorrow morning to discuss. We can use the below dial-in: Dial-in: Code: 707522 Thanks, Assistant United States Attorney Southern District of New York From: Christian Everdell Sent: Thursday, November 5, 2020 4:53 PM To: ).,: >; Jeff Pagliuca •: >; Mark S. Cohen <II. >; Laura Menninger Bobbi Sternheim Cc: (USANYS) Subject: RE: US v. Maxwell - Request for Extension of Discovery Deadline Can we have a call tomorrow morning to discuss? I am free before 9:30am. EFTA00020821 Thanks, Chris From: [mailto: Sent: Thursday, November 05, 2020 1:57 PM To: Jeff Pagliuca; Christian Everdell• Mark S. Cohen; Laura Menninger; Bobbi Stemheim ( Cc: b; I =I(USANYS) Subject: RE: US v. Maxwell - Request for Extension of Discovery Deadline Good afternoon, Thank you for your response. The outside vendor is PAE, which maintains our office's Relativity database. The production at issue consists of documents extracted from numerous electronic devices seized from Jeffrey Epstein's residences in New York and the Virgin Islands, which were loaded onto Relativity for privilege and responsiveness review. On October 7, 2020, our office's filter team completed its privilege review of those documents. On October 21, 2020, the case team completed the responsiveness review and identified approximately 1.2 million documents as responsive. That same night, the case team asked PAE to prepare those approximately 1.2 million documents for production by imaging, bates stamping, and downloading the documents. We have repeatedly told PAE of the November 9th discovery deadline. Yesterday, PAE informed us that it had finished imaging the production but would not be technologically able to finish bates stamping and downloading the production by November 9th. PAE has indicated that it expects to complete the production by November 19th, though it is making every effort to move as quickly as possible. Best, Assistant United States Attorney Southern District of New York From: Jeff Pagliuca Sent: Thursday, November 5, 2020 1:42 PM To: ) ,,t ); Christian Everdell ; Mark S. Cohen < >; Laura Menninger < >; Bobbi Sternheim Cc: (USANYS) Subject: RE: US v. Maxwell - Request for Extension of Discovery Deadline Dear Ms. Because of ongoing difficulty with client calls and visitation we have not been able to adequately discuss the request. Also, it would be helpful for us to know the reason for the anticipated delay and the identity of the vendor. Once we have had the opportunity to fully consider the request we will let you know our position. EFTA00020822 Best regards, Jeff Pagliuca Jeffrey S. Pagliuca Haddon, Morgan and Foreman, P.C. .832.2628 www.hmflaw.com CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages attached to it may contain information that is confidential or legally privileged. If you are not the intended recipient, or a person responsible for delivering it to the intended recipient, you are hereby notified that you must not read this transmission and that any disclosure, copying, printing, distribution or use of any of the information contained in or attached to this transmission is STRICTLY PROHIBITED. If you have received this transmission in error, please notify the sender by telephone or return e-mail and delete the original transmission and its attachments without reading or saving it in any manner. Thank you From: Sent: Thursday, November 5, 2020 10:30 AM To: Christian Everdell < >; Mark S. Cohen c :r4; Jeff Pagliuca ; Laura Menninger ; Bobbi Sternheim ( Cc: (USANYS) Subject: RE: US v. Maxwell - Request for Extension of Discovery Deadline Good afternoon, Following up on the below request, would you please let us know your position? I am available any time this afternoon if you would like to have a call to discuss. We are planning to file our request with the Court today. Thank you, Assistant United States Attorney Southern District of New York From: Sent: Wednesday, November 4, 2020 5:10 PM To: Christian Everdell ; Mark S. Cohen c ;'Jeff Pagliuca' ; Laura Menninger ; Bobbi Sternheim ( EFTA00020823 Cc: (USANYS) Subject: US v. Maxwell - Request for Extension of Discovery Deadline Counsel, Today our outside vendor informed us that it will not be technologically possible for the vendor to finish processing the Government's final discovery production in this case by the November 9, 2020 deadline. The vendor has indicated that it expects to finish processing the production by November 19, 2020, at which point it will send the production to 1 St. Andrew's Plaza for us to conduct a spot check before providing it to you. Accordingly, we intend to ask the Court to extend the final discovery deadline, solely for the production of materials being processed by the vendor, by two weeks to November 23, 2020. We still expect to make a separate discovery production to you on November 9, 2020, and the only material that will be the subject of this extension request is that being processed by the vendor. Would you please let us know your position on this extension request? We are also happy to have a phone call to discuss. Best, Assistant United States Attorney Southern District of New York EFTA00020824