What is document EFTA00028688?

This is an internal email chain dated October 30, 2020 between SDNY prosecutors handling the Ghislaine Maxwell criminal case. The emails discuss delays in receiving processed discovery materials from PAE, a litigation support contractor, and concerns about missing court-ordered deadlines.

Who is mentioned in this document?

The document references Judge Alison J. Nathan, the federal judge presiding over the Maxwell case. Jeffrey Epstein is mentioned in connection with the Relativity workspace containing case evidence. The names of individual prosecutors and contractors are redacted.

What does this document reveal?

The document reveals behind-the-scenes challenges prosecutors faced in the Maxwell case, including significant delays in processing and receiving evidence from contractors. It shows that discovery materials were taking 1-2 months to process, creating 'almost insurmountable timing hurdles' and raising concerns about explaining missed deadlines to the court.

What was the November 9, 2020 deadline about?

November 9, 2020 was the court-ordered deadline for the government to complete production of electronic discovery materials in the Maxwell case. The emails show prosecutors were concerned this deadline could not be met due to contractor delays.

What is PAE and Relativity mentioned in the emails?

PAE appears to be a litigation support contractor handling document processing for the government. Relativity is an e-discovery software platform used to manage, process, and produce the large volume of evidence in the case. The 'US v. Epstein workspace' referenced suggests Maxwell case evidence was stored alongside or built upon Epstein investigation materials.

What is document EFTA00028688?

This is an internal email chain dated October 30, 2020 between SDNY prosecutors handling the Ghislaine Maxwell criminal case. The emails discuss delays in receiving processed discovery materials from PAE, a litigation support contractor, and concerns about missing court-ordered deadlines.

Who is mentioned in this document?

The document references Judge Alison J. Nathan, the federal judge presiding over the Maxwell case. Jeffrey Epstein is mentioned in connection with the Relativity workspace containing case evidence. The names of individual prosecutors and contractors are redacted.

What does this document reveal?

The document reveals behind-the-scenes challenges prosecutors faced in the Maxwell case, including significant delays in processing and receiving evidence from contractors. It shows that discovery materials were taking 1-2 months to process, creating 'almost insurmountable timing hurdles' and raising concerns about explaining missed deadlines to the court.

What was the November 9, 2020 deadline about?

November 9, 2020 was the court-ordered deadline for the government to complete production of electronic discovery materials in the Maxwell case. The emails show prosecutors were concerned this deadline could not be met due to contractor delays.

What is PAE and Relativity mentioned in the emails?

PAE appears to be a litigation support contractor handling document processing for the government. Relativity is an e-discovery software platform used to manage, process, and produce the large volume of evidence in the case. The 'US v. Epstein workspace' referenced suggests Maxwell case evidence was stored alongside or built upon Epstein investigation materials.

EFTA00028688 - EFTA00028689

Internal SDNY prosecutors' email chain from October 30, 2020 discussing critical discovery production delays in the US v. Ghislaine Maxwell case, with concerns about missing Judge Nathan's November 9, 2020 deadline.

This is an internal email exchange between federal prosecutors at the Southern District of New York (SDNY) handling the Ghislaine Maxwell criminal case. The emails reveal frustration over significant delays in receiving processed discovery materials from PAE (a litigation support contractor), with some requested materials taking 1-2 months to be extracted from Relativity (an e-discovery platform). The prosecutors express concern about requiring their team to 'take the hit with Judge Nathan' for missing the November 9, 2020 discovery deadline, and discuss the need for a 'broader or higher level explanation to the Court.'

Key Highlights

•Prosecutors frustrated that discovery requests made in early September 2020 were only arriving in late October
•PAE contractor informed prosecutors it was 'not possible to meet the November 9 date'
•Multiple data productions (SDNYPROD008-014) were being sent via FedEx hard drive
•Prosecutors considered escalating the delay issue to Judge Alison J. Nathan
•References the US v. Epstein workspace in Relativity, showing the Maxwell case built on Epstein evidence

Frequently Asked Questions

Books for Further Reading

Perversion of Justice: The Jeffrey Epstein Story

Julie K. Brown

Investigative journalism that broke the Epstein case open

Filthy Rich: The Jeffrey Epstein Story

James Patterson

Bestselling account of Epstein's crimes and network

Relentless Pursuit: My Fight for the Victims of Jeffrey Epstein

Bradley J. Edwards

Victims' attorney's firsthand account

Document Information

Bates Range

EFTA00028688 - EFTA00028689

Pages

Document Content

Page 1 - EFTA00028688

From: (USANYS)" < To: ll.SYS)" Subject: RE: Phone Call Follow-Up Date: Fri, 30 Oct 2020 18:42:13 +0000 Inline-Images: image001.png (USANYS)" Understood From: USANYS) Sent: Frida October 30, 2020 2:41 PM To: (USANYS); -[USANYS) Subject: RE: Phone Call Follow-Up Thanks, The problem is the stuff that is coming today is stuff the team asked PAE to process in early September. I realize that this is a big project and that there's only so much that can be done, but it poses almost insurmountable timing hurdles for our team if it is taking 1-2 months for PAE to get us stuff we ask for out of Relativity. In most of our cases, this one included, that eats up a huge chunk of the time we have available to produce discovery. We'll follow up early next week to see if there is a more concrete update, but I think this may require a broader or higher level explanation to the Court. I am concerned about requiring our team to take the hit with Judge Nathan for missing this deadline. From: USANYS) < Sent: Friday, October 30, 2020 12:51 PM To: (USANYS) Subject: FW: Phone Call Follow-Up Some of the data is being sent to use today by FedEX. However, there is a ton of stuff still being processed. That stuff is still being imaged. Then it gets marked. Then copied to us. I have spoken to He thinks it is not possible to meet the November 9 date. He thinks the next step might be done on Tuesday, and then a better estimate of completion might be possible. (USANYS) < From: US] < Sent: Friday, October 30, 2020 12:25 PM To: USANYS) Cc: (USANYS) [Contractor] < Subject: Phone Call Follow-Up Good Afternoon Ed: Following up on our earlier phone conversation, a hard drive with the following productions is being sent to SONY via FedEx with the following productions in the US v. Epstein workspace: 1) SDNYPROD008 2) SDNYPROD009 3) SONYPROD010 4) SDNYPROD011 (Note: this is a six-part production) 5) SDNYPROD012 6) SDNYPROD013 7) SONYPROD014 There are approximately 1.2 million records currently being imaged. The images will be available on Monday November 2 2020 at the earliest. The production of the records will begin as soon as the images are available in the workspace. Please feel free to contact me if you have any questions. Thanks, EFTA00028688

Page 2 - EFTA00028689

Lead E-Discovery Analyst e. 7799 Leesburg Pike, Suite 300N Falls Church, Virginia 22043 PAE IMPORTANT: The information contained in this message may be privileged, business sensitive, proprietary, copyrighted, protected from disclosure and/or subject to US export controls. If you are not the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please notify me immediately by replying to the message and deleting it from your computer. #-SEC-# EFTA00028689