RE: US v. Maxwell, 20 Cr. 330 (AJN) - non-testifying witness production

A supplemental production of non-testifying witness material is now ready to produce. Attached please find the cover letter and index accompanying this production. Because the production contains audio and video files, it is too large to produce via USA& Would you please provide our office with two drives (128 GB should be more than sufficient) for us to load with one copy for you and one copy to be sent to Ms. Maxwell at the MDC?

One thing to note: as indicated in the cover letter, DOJ has recently directed our office to cease production of materials marked with the word "confidential" in order to avoid confusion with markings reserved for classified documents. Accordingly, we have noted the appropriate designation for this production by using the label, "SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17," which references the relevant paragraphs in the Protective Order governing confidential materials. Please let us know if you have any objection to this marking or would like to discuss.

Thank you,

Assistant United States Attorney
Southern District of New York
I St. Andrew's Plaza
New York, NY 10007

Tomorrow morning we have a messenger deliver a 1TB hard drive for Ms. Maxwell and a 128gb thumb drive for the attorneys. Please let us know when it is ready.

Hi —
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Hey,

I have the drives and [x] work on getting them loaded. Are we including anything else on the 1TB drive for Maxwell?

Thanks,

The drive for defense has been loaded, but the drive for Maxwell has not yet been loaded.

Would it be possible to please prep everything in the discovery folder here: Usa.doj.gov \ cloud\ NYS\ StAndrews\Shared\USvEpstein-2018R01618 Discovery\GM 27 Eighteenth Production (2021-07- M)

We are designating the PBS Education Records and the Epstein Photo Book confidential, so please use the new stamp we used for the most recent batch for those materials. The rest do not need a designation.

If that can get done quickly, I'd be inclined to include that production on the drives for tomorrow.

The production is all set to go out. I've stamped the PBSD Education Records and Epstein Photo Book confidential [ ] with the same stamp as was used for the most recent NTW batch. Attached is a drafted cover letter to go along with these materials.