📧 Communication

This document is an email chain from March 2021 between Ghislaine Maxwell's defense counsel (Christian Everdell) and the U.S. Attorney's Office (SDNY) regarding discovery disputes. The defense raises seven specific issues, including the inability of Maxwell to view files on prison computers, missing email attachments (over 109,000), metadata discrepancies suggesting files were created/modified after seizure, and gaps in Bates numbering. The prosecution responds by explaining technical limitations with the MDC (prison), asserting that metadata reflects the state of files upon FBI seizure or carving, and clarifying that certain images came from physical CDs seized from Epstein's residences in 2019 rather than electronic extractions.