Text extracted via OCR from the original document. May contain errors from the scanning process.
From:
(USANYS)"
To:
(USANYS)"
I'm talking to the team about discovery generally at 3, so if there have been any developments, or, in particular, anything
more I should be asking them, let me know.
From:
(USANYS) <
>
To:
(USANYS)
As expected, FBI is pretty resistant to using a vendor. I explained to
that we just can't mess around with this
anymore. She is going to get updated information about status and we will talk again later today (her team told her that
we have been provided with roughly 30 of 52 devices, so obviously our information is not matching up).
From:
(USANYS) <
To:
(USANYS) <
Pretty sure it's everything. The estimate references 57 devices, as noted below, I think we're now up to 62, but we're into
one of them, so really 61. We can get an updated estimate for the 61 if that would be helpful, but given how much
business the PC unit gives
he should be good to us on that...
From:
(USANYS)
To:
(USANYS)
What is the estimate for? All of these? Just UVI?
From:
(USANYS)
To:
(USANYS)
Yes, there are a total of 62 devices which can be divided into three main buckets based on how/where we obtained them,
the second and third of which are by far and away the biggest:
•
1 Phone and 1 iPad seized from Epstein at the time of his arrest on July 6, 2019. The FBI first delivered copies of
the extractions from these devices last week. We were able to review the iPad, but we have not been able to
open the iPhone data. IS THIS AN FBI TRANSMISSION ISSUE WITH THE IPHONE DATA, OR IS IT THAT IT WAS UN-
OPENABLE?
•
33 electronic devices seized from the New York residence on July 11, 2019. These include multiple hard drives,
multiple computers, multiple USB drives, and multiple iPads. We currently have extractions from/access to none
of them.
EFTA00026979
•
27 electronic devices seized from the Virgin Islands residence on August 12, 2019. These include multiple
computers, multiple iPads, and multiple USB drives. We currently have extractions from/access to none of them.
From:
(USANYS) •c
>
To:
(USANYS)
<
Can you have the team summarize status of different buckets of devices for me? I'll push this to resolution,
possibly through vendor.
On Jul 2, 2020, at 7:13 PM,
(USANYS) <
wrote:
Let's discuss. I just don't have a lot of confidence that is going to get this done.
Sent from my iPhone
On Jul 2, 2020, at 6:35 PM,
(USANYS)
> wrote:
Ok. Audrey is also prepared to call
about pushing this issue if need be.
On Jul 2, 2020, at 6:32 PM,
(USANYS) <
wrote:
On this issue of the Epstein devices, the team got an estimate from BRG that seems reasonable in terms of both cost
and time line. At this point, I would be inclined to do this, but let's find some time to chat more about it tomorrow if
you're around or early next week if that's better. Thanks
From:
To:
(USANYS)
Cc:
(USANYS)
Following up on the below, I think we've given this our absolute best efforts with FBI — they are now well over a
month later than their estimate from April on when we would get the New York materials, they're also past their
estimate of getting us the New York materials from just this Monday, and we don't have anything close to an
estimate on the USVI materials, which constitute the overwhelming majority of the data and are vastly more
voluminous than the New York devices. We have kept pushing the timeline back for this option, hoping that CART
will finalize, but I think at this point we should have a vendor do it.
Attached is an estimate we got from BRG, which would get everything to us in under a month, and in Relativity-
friendly format, in a range of $85-135K. BRG has done this for our office multiple times in the past and are very
effective and efficient, and they get the materials we need. And most importantly, they estimate they can do it all in
less than a month. May we have approval to seek funding for this? The estimate is attached. Thanks very much.
EFTA00026980
From:
To:
(NY) (FBI)' c
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Cc:
(USANYS)
<
(FBI) <
(USANYS) <
(USANYS) [Contractor]
(NY) (FBI) <->;
Checking in for the estimate of when we can expect to get all the USVI materials?
thanks,
From:
To:
. (NY) (FBI) <
>;
Cc:
(USANYS)
)
(FBI) <
(USANYS)
(USANYS) [Contractor]
(NY) (FBI) <
(NY)
(NY)
Okay thanks — good luck with the cardiologist! And if you can let us know tomorrow that would be great. Thanks
again.
From:
(NY) (FBI) <
>
To:
(USANYS) [Contractor] <
>;
Cc:
(USANYS)
'c
›;
(NY) (FBI) <->;
(FBI) <
(USANYS)
When I'm in the office tomorrow, I will be better able to estimate. I'm at my cardiologist right now.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
(NY)
On Jun 29, 2020 12:56 PM, '
wrote:
Great, thanks. Is there even a rough estimate of when we will get the USVI materials? Or an estimate of when you'll
be able to see how many items to export, so we'll have a better sense of when we'll get those?
EFTA00026981
From:
(NY) (FBI) <
>
To:
(USANYS) [Contractor] a
Cc:
(USANYS)
(NY) (FBI) <->;
(FBI) <->;
(USANYS) <
Yep
NY CART Coordinator
Senior Forensic Examiner
cell
desk
(NY)
>
On Jun 29, 2020 12:52 PM, '
PO
wrote:
Okay, and I'm sorry to ask again, but to make sure, in this production, you're sending us new versions of what you
previously sent?
From:
(NY) (FBI) <M
>
To:
(USANYS) [Contractor] <a;
Cc:
(USANYS)
<
(FBI) <->;
(USANYS)
(NY) (FBI) <->;
You are getting both NY and USVI. The biggest stumbling block are the newer Mac items that are in APFS
(there are a bunch from the Island,) so it is difficult to estimate how long those will take until I see how
many items I have to export.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 29, 2020 12:40 PM, '
wrote:
Okay thanks, and just to clarify, a few days to finalize the New York materials, and then what about the USVI
materials? I think that is quite a bit more. Just looking for an estimated completion date for everything.
II <
And on my other question — does this mean you're giving us a new, complete copy of everything from both NY and
USVI?
thanks,
IM•
EFTA00026982
From:
(NY) (FBI) <
>
To:
(USANYS) [Contractor] a
Cc:
(USANYS) <
(NY) (FBI) <
I a
(NY)
(FBI) <
(USANYS)
I am in the process ofAtoorting the materials (documents, spreadsheets, emails, etc) for your review as per
my discussions with =.
Most of the NY stuff is done, just Mac items left. This might take a few days as
1 item in particular has over 500,000 emails. We will be able to provide discovery once Defense Council
has provided drives for us to copy items over to. This goes quicker as there is no processing involved. ni let
you know when everything is complete.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 29, 2020 11:03 AM, "
wrote:
<
Following up on this, I understand from
that she was able to provide you with a 12 TB drive last week — could
you please let us know when we will be able to get the materials? I expect a judge will ask us about discovery as
early as this week.
Also, the related critical question that I don't think we have clarity on is whether you're giving us a copy of everything
that was collected (including reproducing the materials that you previously gave us, but which are not searchable), or
have you and
figured out a way to categorize the prior productions so they're useful for us? We would strongly
prefer to just get everything at once in a usable format, but please let us know if you expect to produce materials
differently than that.
thanks,
From:
(NY) (FBI)
To:
(USANYS) [Contractor] a
Cc:
(USANYS) <
(NY) (FBI) <->;
) <
`:
=>
(NY)
(FBI) <->;
(USANYS)
We are going every other day now, ramping up to 75% week after next. I need drives to put things on like
and I discussed earlier. Once I have those drives, it will take me a couple days to copy stuff LMK
when I can expect the drives. Thanks.
NY CART Coordinator
EFTA00026983
Senior Forensic Examiner
cell
desk
On Jun 19, 2020 1:09 PM,'
PO
wrote:
following up on the below — please let us know? Given case developments in recent days, this has become
urgent. Thanks.
From:
To:
. (NY) (FBI) <
>;
Cc:
(NY) (FBI)
(USANYS) [Contractor]
(NY) (FBI) <
>;
(USANYS)
(USANYS) <
Wanted to circle back on this and check in, particularly because we desperately need to get the results from the July
and September searches before moving forward with possible additional charges in the case. I know you had
mentioned you needed to push back your prior estimate of complete production by early June, by a couple weeks, so
wanted to see what the current estimate is? I don't think we've started to get anything yet but please correct me if
I'm wrong.
thanks,
From:
(NY) (FBI) <
>
To:
(USANYS) [Contractor] <
>;
Cc:
(NY) (FBI) <
:>;
)
(NY) (FBI) <
>
Will do.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun I, 2020 4:26 PM, '
)" <
wrote:
Understood, and thanks for letting us know. Let's keep in touch both on timing and also on whether there's a way to
identify and categorize what's already been produced, or if we'll need to just get all the raw data at this stage and go
from there.
From:
(NY) (FBI) <
>
EFTA00026984
To:
(USANYS) [Contractor] <a;
Cc:
(NY) (FBI) a;
(NY) (FBI) <M
>
Unfortunately, recent events and our staffing levels have conspired to put a kink in just about everything. If
we can't make heads or tails of the stuff I've already produced, we'll do it again. They have told us that our
staffing levels will be steadily increasing over the next few weeks, but I'm going to have to push back my
estimate by a week or 2. Sony about that. My next day in the office is Thursday, so I'll be able to see if I can
easily identify what I already gave you and marry it to a reliable identifier.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 1, 2020 4:13 PM, '
I/
Thanks for this update — we'll take a look and circle back if any questions.
wrote:
Separately, to follow up on a question from the May 15 email below, the list has just five devices as still pending to be
transferred to us, and I think it's right that the plan is to reproduce all the materials so that we can get them in
searchable format, but just wanted to confirm? Currently, we aren't able to match any of the prior productions to
specific devices — so if we're able to match them up by Bates number now, that might work, but otherwise I think it
makes sense for us to get everything. But let us know if any issue with that.
And related to that question, are we still on track to get the full range of data in the next week or so? I don't think
we've gotten any updates on that status in the past few weeks, and we're eager to be able to start reviewing.
thanks again,
From:
(NY) (FBI) <a>
To:
tz
>
Cc:
(NY) (FBI) <a›;
(USANYS) [Contractor]
>
(NY) (FBI) •ca>
Updated item descriptions. Just a side note, many thumb drives and SD cards will not have a serial number
visible externally, but will report one through our tools. I included those electronically reported serial
numbers. Any questions, let me know.
FBI NY CART Coordinator
EFTA00026985
Senior Examiner
From:
(NY) (FBI) <
>;
Cc:
(NY) (FBI) <->;
(USANYS) [Contractor]
(NY) (FBI) <
Thanks for this, it's a helpful start. In terms of being able to write our search warrant, one additional piece of
information we need is the serial number, or some other specific identifier, ideally for each device but at least for any
device that there is more than one of the same thing. So for example, we need to be able to somehow differentiate
the following devices —
The two Dell power edge T310 hard drives (NYCO24323 and NYCO24324)
The two Sony Vaio laptop / Fujitsu hdd (NYCO24336 and NYCO24337)
the following loose storage devices:
o Micro SD card (NYCO24339)
o Flash Drive (generic) (NYCO24340)
o Thumbdrive (Emtec) (NYCO24341)
o hard drive (loose) (NYCO24342)
o verbatim thumbdrive (NYCO24343)
The four San Disk cruzer-thumbdrives (NYCO24344-47)
The three Seagate IDE hard drives (NYCO24348-50)
The camera SD card (NYCO24351)
I think the rest of the devices are either specifically distinguishable and/or have an S/N listed. (By comparison, the
USVI spreadsheet we have lists an s/n for about 20 of the 25(ish) devices.
The other thing we're looking for is the location in the house (and ideally specific location) for each device, which the
USVI list also has — is that info available?
The list also has just five devices as still pending to be transferred to us, and I think it's right that the plan is to
reproduce all the materials so that we can get them in searchable format, but just wanted to confirm? Currently, we
aren't able to match any of the prior productions to specific devices — so if we're able to match them up by Bates
number now, that might work, but otherwise I think it makes sense for us to get everything. But let us know if any
issue with that.
thanks very much,
IM•
From:
(NY) (FBI) <
>
To:
Cc:
(NY) (FBI) <>
;-.
(NY) (FBI) <
>
<
>)
(USANYS) [Contractor]
EFTA00026986
Here is The listing of all the evidence gathered in NY that I have. I added some columns to guide you to the
unique numbers CART NY uses fro their evidence. The template wasn't a slam dunk over, so I did what I
could to convey the information. If you are confused by anything, please let me know. In the column for
approximate size, it is in GB, totaled at the bottom and converted to TB. In the materials contained column,
I put what load file group the data was transferred over in (Mac, Windows, Loose Media, IDE, or Blacklight)
If there is no entry in that column, that data has yet to be transferred. There are 2 Macs and a DVR you
don't have as well as an iPhone and an iPad. IF the descriptions are a bit light, let me know and I'll do what
I can to beef them up. I will get you the Island stuff tomorrow.
FBI NY CART Coordinator
Senior Examiner
From:
To:
. (NY) (FBI) .:
>;
(USANYS) [Contractor]
Cc:
I
1ce;
(NY) (FBI) 'c
>:
(NY) (FBI) <
>
Respectfully, I think there are some miscommunications here — all we have asked is to receive the materials in a
format such that we can view them using a system we have access to. We're not able to get web-enabled access
through any FBI tool, so we asked for the materials to be transferred in a loadable format so we could put them on
Relativity, which both we and the agents can access. We're required to have the files in a format that we can
produce them to defense counsel. I've done that in many other cases and it hasn't previously been an issue. My
understanding from
is that the best way to do it now is just for us (the U.S. Attorney's Office) to get the original
files, which our vendor will process—by which I just mean converting into file formats that are loadable onto
Relativity. It doesn't really have anything to do with the taint review—we have to have access to the docs in our
systems for discovery purposes.
And we were happy to get the materials as they were processed, but when we received the 1.1 million documents
earlier this year, they were in a format that wasn't usable for the reasons described in the email I sent on March 9.
Again, I understand from
that the best way forward is to just get copies of the materials in their original
formats, which I understand will be segregated and designated by device. That should work for usl I was just trying
to understand the approach, as well as the timeline.
thanks,
From:
(NY) (FBI) <
>
To:
;
(USANYS) [Contractor)
Cc:
EFTA00026987
(NY) (FBI) .:
>;-.
(NY) (FBI)
Just to be clear. The US Attorney's Office (or it's contractors) are not "processing" anything. You are taking
files that I will be extracting from processed evidence and putting them into an E-Discovery tool (Relativity)
to do a taint review.
Relativity is NOT a forensic tool. It is incapable of dealing with many things that are found forensically on a
computer like free space, slack space, and system files to name a few. When we started this, and you
insisted you do the taint review in Relativity, I warned you that it was adding months worth of work on top
of what was already done, and that Relativity was incapable of viewing everything. You insisted we do it
this way. So now
and I have come up with a way to fit this round peg into this square hole. We will get
it done.
Sorry it has taken so long, but we are talking about terabytes worth of data over multiple forms of digital
evidence. Phones, tablets, loose media, cameras, DVRs, servers, laptops, and desktop computers. We have
gotten past encryption on multiple devices. When we review devices on such large cases, we usually do it
piece by piece as things are processed, I was unaware that you didn't want to review as things were
processed, that you wanted to do it "all at once", so that added to the delay. Sorry for that. Just a
differentiation of methodology I suppose.
and I feel confident that the method we have come up with will be more consistent and preserve the
attribution of files to devices and links of e-mails to attachments that the load file generation that I did a
while back was lacking.
FBI NY CART Coordinator
Senior Examiner
From:
To:
. (NY) (FBI) <
I>:
Cc:
(USANYS) [Contractor]
Okay, so just to check, you both think that there is not a need to do a test run? You're both comfortable with just
basically sending us copies of everything? I don't totally understand why we couldn't have done that eight months
ago, but regardless of the passage of time, I want to make sure we understand so we can report to our supervisors. I
assume that means that we (at the U.S. Attorney's Office and through contractors) will therefore need to do all the
processing ourselves, correct? And thanks again to you both.
From:
(NY) (FBI) <
::•
To:
(USANYS) [Contractor] <
>;
Cc:
>;
EFTA00026988
Like
said in his earlier email. It will be the raw data and it will be marked so it is easier to attribute it
to a particular device. Problem now is how to get the data to
since he is teleworking.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On May 12, 2020 11:15 AM, '
c
wrote:
I have no doubt you do, but can you please tell us what that plan is? Thanks!
From:
(NY) (FBI) <
>
To:
(USANYS) [Contractor] <
>;
Cc:
I will use the spreadsheet, no problem.
and I ironed out all the details. We've got a good plan moving
forward that will meet your needs.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On May 12, 2020 10:34 AM, "
wrote:
it would be very helpful for us if you could please use the attached spreadsheet in transmitting that info so
we make sure we get all the info we need. I think you had previously sent us a list of certain information that
unfortunately wasn't helpful for us, so we want to make sure we're all on the same page.
In terms of data transfer,
are you just sending a literal copy of all the raw data, and we'll process and upload
it on our end? I ask to make sure we don't lose any searchability — when FBI sent versions before, it had already
been processed. I think what we talked about on the phone a month ago was getting, for example, data from one
device to make sure it transfers correctly, before sending over literally everything — is that still the plan?
thanks,
From:
(USANYS) [Contractor] •,:
>
To:
Cc:
. (NY) (FBI) <
>
Hello=
EFTA00026989
Me and
just finished our phone call regarding the data.
will put together a list of the all of the data
and where the data was collected. I will work to send some hard drives to
so he can begin to copy the data
and send it to us. I will need to figure out a way to get the data off of the hard drives.
Please let us know if there are any questions.
Thank you.
From:
To:
. (NY) (FBI) c
li>;
(USANYS)
(NY) (FBI)
(USANYS)
Cc:
(USANYS) [Contractor] <
>;
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(NY) (FBI) <
Okay thanks — please do let us know if at any point that changes, otherwise we'll look forward to being able to
review the returns in earlyJune. Thanks again.
From:
(NY) (FBI) ca•
To:
(USANYS) ca;
(NW) (FBI) <Ma;
(USANYS)
Cc:
(USANYS) [Contractor] <
>;
(NY) (FBI) <
>
There has been talk of us returning to normal soon, so I don't think it will effect the timeline I initially gave
you. If it does, I'll let you know.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On May 8, 2020 1:58 PM, '
)" <
> wrote:
Understood, thanks—it will be great to get that list on Thursday. As a refresh, the info we are looking for is in the
attached spreadsheet template.
On the returns themselves, do the changes you mentioned mean that the estimate of a month from now for
complete transmission of the search warrant returns is no longer likely? If so could you please let us know what the
current estimate would be, so we can factor that in? Thanks very much.
From:
(NY) (FBI)
To:
(USANYS)
EFTA00026990
Cc:
(NY) (FBI) c
>;
(USANYS) c
)
(USANYS) [Contractor] <
>;
) <M
>;
(NY) (FBI)
Sony for the delay, they reduced us to 1 day a week, so things have been stretched out by a factor of 5. I
will be back in the office on Thursday and will be able to get you the list then as I have to access some of
our systems to do so.
Also,
please reach out to me at one of the numbers below so we can brain storm. Thanks.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On May 8, 2020 12:10 PM,'
wrote:
Y' C
Following up on the below, I think you had said you expected to be able to get us a list of the devices seized from the
search warrants at Epstein's residences in New York and the USVI, as well as from his person upon arrest, in about a
month (during our conference call a month ago) — so wanted to check if we can still expect that very soon? We're
waiting on that list to be able to do an updated search warrant on all of those devices. Please let us know the
current timeline — and also the current timeline on producing the results from those August and September
searches? I think you and
were going to coordinate on that, and you had mentioned you expected we'd have it
a couple months from our call, which would be about a month from now. Wanted to make sure we're still on track.
thanks,
From:
(NY) (FBI)
To:
(USANYS)
(NY) (FBI) c
(USANYS)
Cc:
(USANYS) [Contractor] <
>,
)
(NY) (FBI) <E
>
Ok let's plan on 11am tomorrow morning, I am trying to get an FBI line with a larger capacity but I won't know until
tomorrow am. I will push it out when confirmed.
Thanks
From:
[mailto:
To:
(NY) (FBI) a>;
(NY) (FBI) a;
Cc:
(USANYS) [Contractor]
(USANYS)
(USANYS)
C
EFTA00026991
(NY) (FBI) sc
>
Yes, I can do anytime tomorrow, and
Rozier can also join anytime tomorrow. So whenever is good on your end.
Also, we can host a conference call, but only up to six lines at a time — so if FBI has larger capacity than that let us
know, otherwise I'd propose we do:
3)
4)
5)
6)
/ M, if either of you wants to join (and if not, one of
From:
(NY) (FBI) <
>
To:
(USANYS)
Cc:
. (NY) (FBI) <
>;
(USANYS) e
>
(USANYS) [Contractor] <
>;
<
>;
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› ;
(NY) (FBI) <M
>
Are
available tomorrow for a conference call to discuss this issue?
SSA
FBI New York
On Apr 7, 2020 1:55 PM, "
wrote:
Following up on this from a month ago — I know we're living in a different world than what existed four weeks ago,
but are you at all able to assist while working remotely? This has been pending for almost two months and we still
don't have a very basic list of each device or item that was seized and searched, or for which of those we've received
materials. We're happy to have a call if that would be useful, but as a first step the most basic thing we're looking for
is the info in the template spreadsheet we sent earlier (that's also attached).
thanks,
From:
To:
. (NY) (FBI) 4:
>;
(USANYS)
(NY) (FBI) c
:•;
(USANYS)
Cc:
(USANYS) [Contractor] <
:>;
ca;
(NY) (FBI)
<
>;
EFTA00026992
Unfortunately I don't think this is very helpful to us. Did you take a look at the example spreadsheet I sent on 2/24?
The excel file you sent has descriptions that don't match up to the items listed in the search warrant returns (that we
sent on 2/23), and we don't have the 1B or CART numbers to be able to cross-reference. We also can't tell what you
mean by "loose media" without a specific comparison to what was seized, we don't know which items you're
referring to as "Windows machines," and we can't tell whether the entirety of any particular item has been
transferred, or just partial. For example, it looks like we have gotten very, very few image files, which is surprising.
We have also encountered some very significant problems in trying to review the more than 1 million documents we
recently received:
The data we've received has no way to put any emails and attachments together. So if an email says, "see
the attached flight records," for example, we have no way of linking that up with the records themselves.
Not only is that a big problem for us in review, it's going to be a huge problem for producing the documents
to defense counsel.
The load file has no link to the native file, so when we load the data to the database, there's no way to have
the native files show up in the database. Because many of the files are too large to open in the viewer, it
effectively means that there are many files that are completely invisible to us.
Related, the control numbers in the load file don't match up to the native files. So we have two sets of
numbers and no way to match up anything—that is, even if we were to try to go hunt down every individual
large file in the native files, it would be impossible.
So the data that we most recently got, we need to get in a form that addresses those issues, and we likely will need
to get a similar reproduction of the data we received a couple months ago. Otherwise we're sifting through more
than a million documents without much rhyme or reason.
I've re-attached the spreadsheet we sent last week — I think that's a good place to start in terms of our necessary
record-keeping, and we need that info at the very least, as well as anything else you think would be useful. Also
attaching the SW returns for reference. And again, we're happy to meet up anytime and hash all this out in person if
that's useful.
thanks,
From:
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Here is a listing of what I have already handed over in load files to the US Attorney's Office for taint review. Some
points of clarification: There were 9 IDE hard drives found in the Manhattan apartment, they turned out to be 3
copies of 3 drives (9 drives in total) from a July 2007 search on one of his properties. I only processed 3 (as they were
all copies). All the loose media from the NY apartment is included. All the Windows machines from the NY apartment
are included. Only 2 Macs from NY and 1 from the Island are included.
I will have to more closely coordinate with whoever is loading up Relativity with the remaining Macs as the
tool they have to be processed with does not easily re-name the load files.
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Spreadsheet is attached.
NYO CART Coordinator
Senior Forensic Examiner
(office)
(cell)
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I could do Thursday morning, but I think it would be helpful for us to get the accounting in advance of the meeting so
we can figure out in advance what (if any) additional steps we need — is that possible?
From:
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Can we do Thursday morning? My network should be back by then and I can give you a good accounting.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Mar 2, 2020 11:15 AM, NI
wrote:
Doing the weekly check in on this — is there a time this week when everyone can meet on this?
thanks,
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Totally understand about the network issues—we can relate. I do still think it will be helpful to all sit down together
to have an in-person discussion, to make sure everybody is on the same page. Are folks available for that next
week? And what I think would be most helpful to facilitate that would be a spreadsheet of each separate device
referenced in the two search warrant returns, with columns for whether we've dumped the contents, whether
they've been reviewed and/or transferred, what portions were transferred, etc.
Something roughly like the attached, with any other categories you think would be useful — and the info on the
attached is mostly hypothetical, obviously, just as examples. That will help us fully understand what's been reviewed,
transferred, and received so far, and what remains.
(Also just on the pictures, we do want copies of those as well, please including from the discs and the devices — I
think FBI was going to do an initial screen to make sure no CP, and since I think the answer was no, we'll need to get
those to be able to review them as well.)
many thanks,
From:
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Sorry for the delayed response. They are tearing out our old network and giving us a new one, they
mandated we delete old stuff (about 400 TB worth). Now that they are working on replacing the network,
we can do only local work. I should be able to give you an accounting of what is what. I can say, off the top
of my head, that all windows based items from the NY search have been handed over as well as all loose
media. The CDs from NY only contained pictures, no documents. There are still some Apple items from NY
that need to be produced. As far as the Island stuff goes, the 1st item on your spreadsheet, the "kitchen" mac
has been produced. Still working on the rest.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Feb 23, 2020 12:21 AM, '
wrote:
Team,
II <
Following up on the below from last weekend, I'm still not sure how we're addressing this so I thought it would make
sense for us to all schedule a (hopefully relatively brief) meeting to all get on the same page? We didn't hear back on
which files had previously been provided, but our tech folks did their best to differentiate, and we got access to the
materials yesterday and its well over a million documents, and we don't have any idea what we're looking at — i.e.,
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which devices the materials came from, whether it's full or partial results, how many more devices we have coming,
etc.
Based on the attached search warrant returns, it looks like from the New York mansion (the PDF) there are
approximately 40 devices that would have storage (computers, hard drives, thumb drives, etc.) and that's not even
counting at least 60+ CDs. And then from the Virgin Islands (the Excel spreadsheet), at least more than 25 devices,
including multiple servers / server racks.
So we gotta know what we've already received, what remains, anticipated schedule, etc, and I know it's a lot of
moving pieces on all sides so wanted to loop in everybody at once. The case team will be in California this coming
week from Tuesday through Friday, but then I think generally around the first week of March, which will hopefully be
plenty of time to schedule a productive meeting.
thanks all,
IM•
From:
To:
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I'm not sure who's the exact right person to ask this, so wanted to get everybody on one email chain about it — I have
the hard drive that
dropped off that has new Epstein search warrant materials, but it looks like there are also
old materials (that I think we had previously received and uploaded??) on the hard drive, and so I'm not sure what's
new.
Just generally, and
and I talked about this last week too, but it's basically impossible for us to keep track of
what we're getting, and what has been completed, without some kind of identification or labeling system, along with
a list of which devices have been extracted and downloaded.
So for example on the hard drive currently, there are 38 folders labeled "loadFiles" through "37loadFiles" with a
modified date of 11/14/19, which I think we may have already previously received — but I'm not sure, because we
haven't gotten any info on which folders match up to which devices, etc. And then there's another folder titled
"NYC024362" that has a modified date of 1/27/20, so I think that may be the materials we hadn't previously
received? That folder by itself has more than 600,000 items.
I don't want to give
anything that we've already previously received and uploaded, and I can't tell from the
folder or file names whether everything on the drive is new, or whether just additional materials were saved onto it
in addition to what we already have. =,
are you able to give us some guidance on this? Ultimately what we
really need is a spreadsheet of every device, whether it's been dumped (or partially dumped), and then identifying
that same info — which device, and what materials from it — are being given to us with each data transfer. Otherwise
I think organizationally and for review purposes it will be a total disaster for us.
We're happy to have a meeting on this if that's helpful — and thanks everybody for the assistance.
Assistant U.S. Attorney
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Southern District of New York
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