This is an internal email chain between federal prosecutors and legal staff coordinating the production of FBI files from Florida for Ghislaine Maxwell's discovery in October 2020.
This October 2020 email exchange shows prosecutors organizing discovery materials for the Ghislaine Maxwell criminal case. The emails discuss technical issues with accessing the correct subset of FBI files from Florida within a Relativity e-discovery database containing over 26,000 documents. The team is working to produce specific tagged materials to the defense, with a deadline to deliver to St. Andrews Plaza (the SDNY federal courthouse) by the end of October 2020.
From: To: Cc: Subject: RE: Discovery Tasks for Maxwell on Epstein Relativity Databases Date: Wed, 14 Oct 2020 16:27:04 +0000 Thanks very much. From: Sent: Wednesday, October 14, 202012:22 PM To Subject: RE: Discovery Tasks for Maxwell on Epstein Relativity Databases It is possible I sent you the wrong link. I am currently in the White Plains office sending out a hard drive for the production. I will check the link when I get back to my computer and have my RSA token. Thank you. From: Sent: Wednesday, October 14, 2020 10:48 AM To: Subject: RE: Discovery Tasks for Maxwell on Epstein Relativity Databases Thanks When I click on the link you sent, it brings me to the "FBI Files from Florida Office" folder, but it appears to bring up all 26,164 documents in that folder, when the production should be a smaller number of documents bearing the tags I listed below. Are you free for a call to discuss? From Sent: Wednesday, October 14, 2020 10:02 AM To: Cc: Subject: RE: Discovery Tasks for Maxwell on Epstein Relativity Databases Good Morning Thank you for the e-mail. Just to confirm can you please review the below search and let me know that everything that is in the search is everything you wish to produce for item three. I want to make sure that we have everything you need before we start the imaging process. EFTA00022047
Thank you. Fro Sent: Tuesday, October 13, 2020 11:17 PM To: Subject: Discovery Tasks for Maxwell on Epstein Relativity Databases Thanks very much for speaking earlier today. As discussed, we are asking for the following three productions to be prepared for the Maxwell case. I've listed those tasks below in the order in which we discussed them, but, as we discussed, if you and the vendor believe a different order would be more efficient, please just let me know. EFTA00022048
As we've discussed, we need all of these materials to be delivered to 1St. Andrews by the end of October in order to meet our discovery deadline. Finally, I believe should be sending you a drive containing the scans of boxes of files from the USAO-SDFL. We need all of those files loaded into the US v Epstein database on Relativity in a new folder entitled "USAO-SDFL Files," ASAP so that we can review them, please. Thanks very much, as always for your help, and please do not hesitate to reach out if there are any questions or confusion. I'm always happy to chat. Thanks so much, EFTA00022049


