FBI W CART Coordinator Senior Examiner From: (USANYS) Sent: Wednesday, May 13, 2020 12:25 PM To: M, I. (NY) (FBI) a (USANYS) [Contractor] Cc: (USANYS) ;IM (USANYS) MI. (NY) (FBI) `: >; (FBI) a> Subject: RE: Epstein search warrant documents I. (NY) 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 dots 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 us! I was just trying to understand the approach, as well as the timeline. thanks, From: 1=1, 1 (NY) (FBI) a> Sent: Tuesday, May 12, 202013:03 To: (USANYS) < Cc: MI (USANYS) `Ma >. NM (NY) (FBI) < Subject: Re: Epstein search warrant documents >;M. (USANYS) (Contractor) (USANYS) ; I. (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 3503-039 Page 11 of 21 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00002153 EFTA00157333

(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: (USANYS) Sent: Tuesday, May 12, 2020 11:33 AM To: (NY) (F80 (USANYS) [Contractor] Cc: (USANYS) (USANYS) Subject: RE: Epstein search warrant documents 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: I. (NY) (FBI) < > Sent: Tuesday, May 12, 2020 11:30 To: M, (USANYS) (Contractor] <a; (USANYS) Cc: M, M(USANYS)< '; (USANYS) < Subject: RE: Epstein search warrant documents Like said in his earlier email. It will be the raw data and it will be marked so it is easier to 3503-039 Page 12 of 21 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00002154 EFTA00157334