Skip to main content
Skip to content
Case File
efta-efta00089749DOJ Data Set 9Other

Subject: RE: Status update: Maxwell discovery issue files review

Date
Unknown
Source
DOJ Data Set 9
Reference
EFTA 00089749
Pages
6
Persons
2
Integrity
No Hash Available

Summary

Subject: RE: Status update: Maxwell discovery issue files review Date: Fri. 21 May 2021 02:43:49 +0000 Great, thank you! From: (USANYS) [Contractor] .ca. Sent: Thursday, May 20, 2021 10:00 PM To: ) Cc: (USANYS) [Contractor] cl > (USANYS) *c )'; Subject: RE: Status update: Maxwell discovery issue files review (USANYS) [Contractor] The two part upload worked, and the production is ready to be shared with defense counsel once we have their info to set them up on USAfx. I'll be online for a bit longer tonight in case they get back to us ASAP with that, otherwise I'll add them in the morning. Thank you very much for your patience, and we'll get the production sent out on a disc for Maxwell at MDC tomorrow. From: Sent: Thursday, May 20, 2021 8:38 PM To: (USANYS) [Contractor] Cc: (USANYS) [Contractor] < 4 Subject: RE: Status update: Maxwell discovery issue files review (USANYS) (USANYS) [Contractor] Thanks! Let me know once you've tried the split upload. Once I he

Tags

eftadataset-9vol00009
Ask AI about this document

Search 264K+ documents with AI-powered analysis

Extracted Text (OCR)

EFTA Disclosure
Text extracted via OCR from the original document. May contain errors from the scanning process.
Subject: RE: Status update: Maxwell discovery issue files review Date: Fri. 21 May 2021 02:43:49 +0000 Great, thank you! From: (USANYS) [Contractor] .ca. Sent: Thursday, May 20, 2021 10:00 PM To: ) Cc: (USANYS) [Contractor] cl > (USANYS) *c )'; Subject: RE: Status update: Maxwell discovery issue files review (USANYS) [Contractor] The two part upload worked, and the production is ready to be shared with defense counsel once we have their info to set them up on USAfx. I'll be online for a bit longer tonight in case they get back to us ASAP with that, otherwise I'll add them in the morning. Thank you very much for your patience, and we'll get the production sent out on a disc for Maxwell at MDC tomorrow. From: Sent: Thursday, May 20, 2021 8:38 PM To: (USANYS) [Contractor] Cc: (USANYS) [Contractor] < 4 Subject: RE: Status update: Maxwell discovery issue files review (USANYS) (USANYS) [Contractor] Thanks! Let me know once you've tried the split upload. Once I hear from you, I'll email defense counsel. From: (USANYS) (Contractor) .‘z . Sent: Thursday, May 20, 2021 8:38 PM To: ) Cc: (USANYS) [Contractor] (USANYS) [Contractor] c:= > (USANYS) Subject: RE: Status update: Maxwell discovery issue files review ust had the idea to try and split the production into two smaller uploads to put on USAfx, so I'm going to try that and see if it works. Otherwise I'll put it on a disc in the morning for counsel and for Maxwell, though it might be worth noting (either just among us or to defense counsel) that if she can't view non pdf image files she will not be able to view the vast majority of this production. From: Sent: Thursday, May 20, 2021 8:31 PM To: (USANYS) [Contractor] Cc: (USANYS) [Contractor] < (USANYS) EFTA00089749 (USANYS) [Contractor) Subject: RE: Status update: Maxwell discovery issue files review Ok, no problem. Will you also be able to put it on a disc to send to the MDC for Maxwell, please? From: (USANYS) [Contractor] .cz > Sent: Thursday, May 20, 2021 8:30 PM To: ) tz > Cc: cfl (USANYS) [Contractor] <E > (USANYS) Subject: RE: Status update: Maxwell discovery issue files review (USANYS) [Contractor) Actually, unfortunately, the production has failed to upload to USAfx, so we may just need to stick it on a disc tomorrow morning. From: (USANYS) [Contractor] Sent: Thursday, May 20, 2021 8:24 PM To: ) Cc: (USANYS) [Contractor) (USANYS) [Contractor] c > (USANYS) Subject: RE: Status update: Maxwell discovery issue files review Feel free to email defense counsel, the production is uploading to USAfx now. We'll just need the email addresses and cell phone numbers to make USAfx accounts for whoever they want to have access to the production (defense counsel or their litigation support people or whoever) so we can share it with them once it's uploaded. Thank you! From: Sent: Thursday, May 20, 2021 8:17 PM To: (USANYS) [Contractor] Cc: (USANYS) [Contractor] cfl > Subject: RE: Status update: Maxwell discovery issue files review (USANYS) (USANYS) [Contractor) Perfect, thank you! This is ready to go. Ok for me to email defense counsel with the letter and spreadsheet now? Or do you need any more time to prep the production? From: (USANYS) [Contractor] •<M > Sent: Thursday, May 20, 2021 7:59 PM To: ) Cc: (USANYS) [Contractor) (USANYS) [Contractor] c > (USANYS) Subject: RE: Status update: Maxwell discovery issue files review Updated discovery letter is attached (saved here) with the spreadsheet as well for reference. Let me know if you have any additional revisions. From: Sent: Thursday, May 20, 2021 7:15 PM EFTA00089750 To: (USANYS) [Contractor] < Cc: (USANYS) [Contractor] < (USANYS) (USANYS) [Contractor] Subject: RE: Status update: Maxwell discovery issue files review Perfect, thanks. Let's plan to jump on a call at 7:30. From: (USANYS) [Contractor] Sent: Thursday, May 20, 2021 7:15 PM To: Cc: (USANYS) [Contractor] < (USANYS) <a>; (USANYS) [Contractor] Subject: Re: Status update: Maxwell discovery issue files review I will be home in 5-10 if that's okay with you all to wait just a few min? Sent from my iPhone On May 20, 2021, at 7:13 PM, > wrote: That sounds good! I've reviewed what=ent. Are you all available to hop on a call now? From: (USANYS) [Contractor] < Sent: Thursday, May 20, 2021 6:26 PM To: Cc: (USANYS) [Contractor] < >; >; Subject: RE: Status update: Maxwell discovery issue files review (USANYS) < (USANYS) [Contractor] >; I think we're all around to hop on a call tonight. We were thinking it would be efficient to discuss the materials that Must sent around on the same call. Let us know if you'd like time to review those materials before hopping on the call. From: Sent: Thursday, May 20, 2021 6:12 PM To: (USANYS) [Contractor] < >; (USANYS) Cc: (USANYS) [Contractor] < >; Subject: RE: Status update: Maxwell discovery issue files review (USANYS) [Contractor] Thanks so much! Can we hop on a quick call to talk this through? Either this evening or tomorrow morning is fine. From: (USANYS) [Contractor] < Sent: Thursday, May 20, 2021 5:10 PM To: >; (USANYS) < >; Cc: (USANYS) [Contractor] < >; (USANYS) [Contractor] EFTA00089751 Subject: RE: Status update: Maxwell discovery issue files review Hi Attached is the spreadsheet with each problem file that Maxwell's counsel listed and our corresponding notes. This does not include the "Images Not Exported" section as we are having sre-export those for us to double check. There is one group of files that we'd like to bring to your attention: In the "Corrupt" tab of the spreadsheet you'll see that there are a number of files which are labeled "Lazer Scan." These are the same files that we dealt with last August/September (linked here) which I believe we worked out to be 3D renderings and scans of Epstein's compound. and I both recall dealing with this extensively but are having trouble locating emails documenting that fact other than the attached. Happy to discuss over the phone if you'd like and determine a better way to mark them in the spreadsheet. Besides that, the list of files should be good to go. And we can inform counsel tonight that we are already working with the vendor to address any files we found to have any issues. Please let us know if you have any questions or comments on the spreadsheet. Thanks, From: Sent: Thursday, May 20, 2021 11:58 AM To: (USANYS) [Contractor] (USANYS) Cc: (USANYS) [Contractor] 4 ); (USANYS) [Contractor] Subject: RE: Status update: Maxwell discovery issue files review Great, thanks. I'll send an invite for 1:30. From: (USANYS) [Contractor] •c Sent: Thursday, May 20, 2021 11:54 AM To: (USANYS) Cc: (USANYS) [Contractor] 4 (USANYS) [Contractor] Subject: RE: Status update: Maxwell discovery issue files review Of course==, and I are all available from 1pm on. From: Sent: Thursday, May 20, 2021 11:53 AM To: (USANYS) [Contractor] c Cc: (USANYS) (USANYS) [Contractor] 4 (USANYS) [Contractor] Subject: RE: Status update: Maxwell discovery issue files review His EFTA00089752 Can we have a call to touch base on this today, please? Thanks, From: (USANYS) [Contractor] Sent: Friday, May 14, 2021 5:58 PM To: (USANYS) Cc: < (USANYS) [Contractor] (USANYS) [Contractor] Subject: Status update: Maxwell discovery issue files review Hi all, Here is our status update for the review of discovery files that Maxwell is having various issues with, categorized by issue and whether the file was from a PAE export or something we stamped on the shared. • Blank files o From PAE export (29 pages/files): all but one of these files that were described as "blank" were in fact blank files; nothing more to do for these files. The one non-blank file among these (SDNY_GM_00218894) has no native file that was produced with it (we will look into/confirm with PAE re: whether this was intentional or an oversight), but the image produced for this Bates number should not appear "blank." o From shared drive/stamped by SDNY (308 pages/files): none of these pages were blank. They all were pages within Deutsche Bank records from Production 2. • Corrupt files o From PAE export (501 pages/files): the initial review of these files is complete, and 290 documents were corrupt in their native produced form when we opened them. There are additionally about 160 documents of varying file types that we did not identify as corrupt but had various issues opening or viewing, which could possibly explain why she had an issue with them. We (paras) can confer more about these files early next week and let you know what we think we should do next (e.g., ask PAE to re-export them, determine whether we/she has appropriate software for viewing, etc.). The remaining pages/files among the 501 identified for review in this category are duplicates of other Bates identified as "corrupt." o From shared drive/stamped by SDNY (2152 pages/files): none of the pdf files identified by defense as "corrupt" were corrupt per our review; all files were able to be opened, and all Bates numbered pages were able to be viewed. • However, there is a range of files (SDNY_GM_00169505-SDNY_GM_00169737 from Production 3 (SDNY_GM_00166191-SDNY_GM_00169759 (Search warrant photos))) that defense listed as "corrupt" but they seem to be weird computer/electronic system files. I cannot open these files to see what they are (many seem to be .fls files or other systems-related unknown file types), and I'm not sure if you previously identified what these files are in particular, either internally when initially producing them or to defense counsel. These files can be found here for our reference/review, and we (paras) will again touch base about these next week to determine to what extent we can help her view them (or whether they are even viewable to us). • Missing o From PAE export: pending review of master copy discovery hard drive o From shared drive/stamped by SDNY: neither file is missing/no issues with these files • Can't read/won't open o From PAE export: pending review of master copy discovery hard drive o From shared drive/stamped by SDNY: no issue with these files • Not supported o From PAE export: pending review of master copy discovery hard drive o No files with this issue from shared drive/stamped by SDNY • Images not exported EFTA00089753 o From PAE export: pending review of saved searches from o From shared drive/stamped by SDNY: no issues with these files All in all, the files identified as "blank" and "corrupt" are nearly done being reviewed, and we'll aim to get as much done as we can on the remaining categories in the next week. Let us know if you have questions based on this initial review, and we'll keep you posted as we made additional progress. Thanks, Paralegal Specialist U.S. Attorney's Office I SDNY 1 Saint Andrew's Plaza New York, NY 10007 Office: Cell: EFTA00089754

Related Documents (6)

DOJ Data Set 9OtherUnknown

Subject:

From: To: Subject: - u is airs ews ne Ing e nes ay, u y 29, 2020 Date: Wed, 29 Jul 2020 10:25:50 +0000 c Importan e: Normal Mobile version and searchable archives available at fbi.bulletinintelligence.com. 1B1 News Briefing TO: THE DIRECTOR AND SENIOR STAFF DATE: WEDNESDAY, JULY 29, 2020 6:30 AM EDT TODAY'S TABLE OF CONTENTS LEADING THE NEWS • Barr Spars With Democrats At Contentious House Hearing. • Barr Says Democrats Have Tried To "Discredit" Him. • Barr Says Bash Investigating "High Number Of Unmaskings" During Obama Administration. PROTESTS • Memo Reveals Federal Agents Sought Role In Suppressing Protests Since Start. • New Mexico Governor Addresses Concerns About Federal Agents In Albuquerque. • Report: US, Oregon In Talks About Pulling Agents From Portland. • Portland Fines Federal Government For Unpermitted Fence Outside Courthouse. • US Park Police Head: Decision To Clear Protesters Not Linked To Trump "Photo Op." • Hundreds Of Cases Involving LAPD Off

47p
DOJ Data Set 9OtherUnknown

U.S. Department of Justice

U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Motto Building One Saint Andrew's Plaza New York. New York 10007 July 28, 2020 VIA ECF The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully submits this letter with respect to the protective order to be entered in the above-captioned case, and to respond to the defendant's letter and submission of July 27, 2020 (the "Defendant Letter" or "Def. Ltr.") (Dkt. 29). The Government and defense counsel have conferred regarding a protective order several times via telephone and email between July 9, 2020, and today, including as recently as this morning. The Government and defense counsel have come to an agreement on much of the proposed protective order. However, the parties

7p
DOJ Data Set 9OtherUnknown

From: '

From: ' To:' 1111 Cc: ' >, Subject: Re: RE: Epstein search warrant documents Date: Wed, 17 Jun 2020 19:13:54 +0000 Importance: Normal and I just spoke. We are going to down and take a look at all digital evidence and get this squared away. I'm going to work on getting a large enough hard drive to dump the evidence on to get it to SDNY. From: Sent: Wednesday, June 17, 2020 2:39 PM To: Cc: Subject: Fwd: RE: Epstein search warrant documents I know you already got this, just wanted to confer with you as to what is going on with all this. Feel like you, me, and need to chat and see what is what. I'm thinking that this started before the case took a turn yet is still moving in the same direction. In other words, do we really need to be doing this? Seems to me that I should be taking all my marching orders from and M. NY CART Coordinator Senior Forensic Examiner cell desk From: (USANYS)" Forwarded message Date: Jun 17, 2020 2:28 PM Subject: RE: Epstein search war

14p
DOJ Data Set 9OtherUnknown

Case 9:08-cv-80736-KAM Document 50

Case 9:08-cv-80736-KAM Document 50 Entered on FLSD Docket 0372112011 Page 1 of 15 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 v. UNITED STATES JANE DOE #1 AND JANE DOE #2'S MOTION FOR ORDER DIRECTING THE U.S. ATTORNEY'S OFFICE NOT TO WITHHOLD RELEVANT EVIDENCE COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and through undersigned counsel, to move for an order from this Court directing the U.S. Attorney's Office not to suppress material evidence relevant to this case. The Court should enter an order, as it would in other criminal or civil cases, requiring the Government to make appropriate production of such evidence to the victims. BACKGROUND In discussions with the U.S. Attorney's Office about this case, counsel for Jane Doe #1 and Jane Doe #2 inquired about whether the Office would voluntarily provide to the victims information in its possession that was mater

15p
House OversightUnknown

Defense Claims DOJ Official Misrepresented Deferred Prosecution Agreement Modifications in Epstein Case

Defense Claims DOJ Official Misrepresented Deferred Prosecution Agreement Modifications in Epstein Case The passage outlines a dispute over a purported modification to Jeffrey Epstein's Deferred Prosecution Agreement (DPA) by U.S. Attorney Paul Acosta and SDFL prosecutor Michael Sloman. It suggests possible procedural misconduct or bad‑faith tactics by DOJ officials, which could be a concrete lead for further FOIA requests, interview of the attorneys involved, and review of the December 19, 2007 letter. While the actors are high‑profile (U.S. Attorney, federal prosecutors), the claim is not novel and lacks specific evidence of wrongdoing beyond contradictory statements, placing it in the strong‑lead range. Key insights: Sloman threatened to terminate the DPA unless Epstein complied with a 'unilateral modification' that defense says was never formally agreed to.; The defense asserts the December 19, 2007 letter from U.S. Attorney Acosta only proposed changes, which were rejected by defense counsel.; The SDFL allegedly refused to provide needed information for Epstein to meet the alleged new pleading and sentencing requirements.

1p
DOJ Data Set 9OtherUnknown

UNITED STATES DISTRICT COURT

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA S 120 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x THE GOVERNMENT'S OMNIBUS MEMORANDUM IN OPPOSITION TO THE DEFENDANT'S PRE-TRIAL MOTIONS AUDREY STRAUSS United States Attorney Southern District of New York Attorney for the United States of America Assistant United States Attorneys - Of Counsel - EFTA00039421 TABLE OF CONTENTS PRELIMINARY STATEMENT 1 BACKGROUND 2 ARGUMENT 3 I. Jeffrey Epstein's Non-Prosecution Agreement Is Irrelevant to This Case 3 A. The NPA Does Not Bind the Southern District of New York 4 1. The Text of the Agreement Does Not Contain a Promise to Bind Other Districts 5 2. The Defendant Has Offered No Evidence That the NPA Binds Other Districts 9 B. The NPA Does Not Immunize Maxwell from Prosecution 15 1. The NPA Is Limited to Particular Crimes Between 2001 and 2007 15 2. The NPA Does Not Confer Enforceable Rights on Maxwell 17 C. The Defendant

239p

Forum Discussions

This document was digitized, indexed, and cross-referenced with 1,400+ persons in the Epstein files. 100% free, ad-free, and independent.

Annotations powered by Hypothesis. Select any text on this page to annotate or highlight it.