NY CART Coordinator Senior Forensic Examiner cell desk On Jun 29, 2020 12:52 PM,' < > 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) < > Sent: Monday, June 29, 2020 12:50 To: (USANYS) [Contractor] Cc: (USANYS) (NY) (FBI) <->; c >; (NY) (FBI) c >; (USANYS)< > Subject: RE: Epstein search warrant documents 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. And on my other question — does this mean you're giving us a new, complete copy of everything from both NY and USVI? thanks, From: (NY) (FBI) < > Sent: Monday, June 29, 2020 12:34 To: (USANYS) [Contractor] 4 Cc: (USANYS) . (NY) (FBI) < (USANYS) Subject: RE: Epstein search warrant documents >; (NY) (FBI) I am in the process of exporting 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. I'll let you know when everything is complete. EFTA00030396
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 I= 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) < > Sent: Friday, June 19, 2020 13:14 To: (USANYS) [Contractor] < >; Cc: (USANYS) <IM > 2; (USANYS) Subject: RE: Epstein search warrant documents (NY) (FBI) < >; (NY) (FBI) 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 Senior Forensic Examiner cell desk On Jun 19, 2020 1:09 PM,' < wrote: following up on the below — please let us know? Given case developments in recent days, this has become urgent. Thanks. From: Sent: Wednesday, June 17, 2020 14:28 To: (NY) (FBI) a; (USANYS) [Contractor] < > Cc: (NY) (FBI) a; I c >i (NY) (FBI) •:: :.; (USANYS) (USANYS) Subject: RE: Epstein search warrant documents EFTA00030397
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) < > Sent: Monday, June 01, 2020 16:28 To: (USANYS) [Contractor] < >; Cc: >, (NY) (FBI) Subject: RE: Epstein search warrant documents (NY) (FBI) a; I ; Will do. NY CART Coordinator Senior Forensic Examiner cell desk On Jun 1, 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) < > Sent: Monday, June 01, 2020 16:23 To: (USANYS) [Contractor] < >; Cc: (NY) (FBI) a; Subject: RE: Epstein search warrant documents (NY) (FBI) c > 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. Sorry 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 many it to a reliable identifier. NY CART Coordinator Senior Forensic Examiner cell desk EFTA00030398
On Jun 1, 2020 4:13 PM, " " < > wrote: Thanks for this update — we'll take a look and circle back if any questions. 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) < > Sent: Friday, May 29, 2020 12:53 To: Cc: (NY) (FBI) a>' Subject: Re: Epstein search warrant documents > (USANYS) [Contractor] (NY) (FBI) < > 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 Senior Examiner From: Sent: Friday, May 15, 2020 4:11 PM To: (NY) (FBI) •Ma; Cc: (NY) (FBI) < >; Subject: RE: Epstein search warrant documents (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) EFTA00030399
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, From: (NY) (FBI) < > Sent: Thursday, May 14, 2020 15:54 To: > Cc: < >; (NY) (FBI) < Subject: Re: Epstein search warrant documents >; >; (USANYS) [Contractor) . (NY) (FBI) .z: > 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: Sent: Wednesday, May 13, 2020 12:25 PM To: . (NY) (FBI) .ce (USANYS) [Contractor] EFTA00030400
Cc: e; (NY) (FBI) < >; (NY) (FBI) < > Subject: RE: Epstein search warrant documents 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) < => Sent: Tuesday, May 12, 2020 13:03 To: Cc: (NY) (FBI) < Subject: Re: Epstein search warrant documents S.; >; (USANYS) [Contractor) . (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. EFTA00030401
