- From: [redacted] (USANYS) — sender name and email redacted  
- To: Laura Menninger; multiple other recipients (names/emails mostly redacted), including Jeff Pagliuca (email redacted)  
- Cc: multiple recipients (names/emails redacted), including a "[Contractor]" listed with (USANYS)  
- Subject: RE: US v. Maxwell, 20 Cr. 330 (AJN)

Subject: RE: US v. Maxwell, 20 Cr. 330 (AJN)

Date: Sat, 20 Nov 2021 21:52:41 +0000

Attachments: 2021.11.20_Maxwell_Discovery_Letter_-_Corrected.pdf

Laura,

I'm attaching a corrected cover letter for the discovery production. The letter inadvertently listed SDNY_GM_02774195 instead of SDNY_GM_02774105. We have sent a hard drive to your office in Colorado (the FedEx tracking number is 8166 1429 9380). We have also sent a hard drive to your client at the MDC via FedEx. The tracking number for the drive is 8166 1445 3318, and the tracking number for the password is 8166 1445 3307. We are leaving a hard drive at our office for pickup under Chris's name.

We have uploaded the production except for SDNY_GM_02774100-SDNY_GM_02774104 to USAfx. We could not upload SDNY_GM_02774100-SDNY_GM_02774104 due to size limitations. The materials have been added to the same USAfx production folder shared with you earlier today.

Thanks,



From: [redacted] <[redacted]>
Sent: Saturday, November 20, 2021 4:17 PM
To: [redacted] (USANYS) <[redacted]>; [redacted] <[redacted]>; [redacted] <[redacted]>; [redacted] <[redacted]>
Cc: [redacted] <[redacted]>; [redacted] <[redacted]>; [redacted] (USANYS) [Contractor] <[redacted]>; [redacted] <[redacted]>
Subject: [EXTERNAL] RE: US v. [redacted], 20 Cr. 330 (AJN)



A second question for you — the discovery letter appears to skip bates numbers 2774105-2774194.

Can you please confirm whether that was intentional or let us know what additional documents are contained in that range?

Thank you,
Laura

Email from (USANYS) sent on Saturday, November 20, 2021, at 12:53 PM.

Recipients include Laura Menninger and Jeff Pagliuca.

CC list includes (USANYS) [Contractor].

EFTA00014655

Subject: US v. Maxwell, 20 Cr. 330 (AJN)

Counsel,

We have an additional discovery production ready to send to you. Attached please find the accompanying cover letter. That will be produced on a hard drive to you. In addition, a supplemental production of testifying witness and nontestifying witness material and exhibits are also ready to send to you. Attached please find the accompanying cover letter and indices. Those materials will be on the hard drive as well. We will also produce the testifying witness and nontestifying witness material and exhibits via USAfx.

Please let us know if you would like to pick up the drive today or if you would like us to FedEx it (and if so, to where). Please let us know if you would like us to send today via FedEx a hard drive with these materials to Ms. Maxwell at the MDC or bring the hard drive to court on Tuesday.

- Sign-off: "Thanks,"
- Name: [redacted] (black bar)
- Additional line under name: [redacted] (black bar)
- Title: Assistant United States Attorney
- Office: United States Attorney’s Office, Southern District of New York
- Additional line (likely office address or name): [redacted] (black bar)
- City, ZIP: New York, New York 10007
- Tel: [redacted] (black bar)

EFTA00014656