From: " To: ' Cc: "{ Subject: RE: Epstein search warrant documents Date: Fri, 15 May 2020 19:30:04 +0000 Okay thanks, just wanted to make sure given that column. If you could please confirm with him as he starts to send us stuff, that would be great — we'll basically just want to re-load all that stuff (which, separately, also got uploaded to the wrong folder structure in Relativity so we can circle up on that whenever you get the new info too). Thanks. From: Sent: Friday, May 15, 2020 15:28 To: Cc: < >; Subject: RE: Epstein search warrant documents I mentioned to that the only first delivery we were able to upload to the database and told him the issues with the other two deliveries. I believed that he understands that he needs to replace those deliveries that we could not use. From: Sent: Friday, May 15, 2020 3:25 PM To: Cc: >; Subject: FW: Epstein search warrant documents Following up on our discussions, I think this actually looks fairly useful. The only thing I wanted to highlight to you is that based on this spreadsheet, it seems to say that only five devices from NY have materials that are still outstanding to be transferred to us (looking at the "Remaining to be transferred" column). Just based on what we've gotten so far, I find that difficult to understand (since we have so few overall dots), but even assuming that's right, *anything* in the prior two transfers to us (one hard drive that we did upload, that was all screwed up for the reasons you previously identified, and one hard drive that we didn't upload for the same reasons) needs to be re-transferred based on the format you and have discussed, right? I just want to make sure he doesn't only transfer what he views as "remaining," leaving us with like 95% of the material being in a form that's not useful for us. And figured I'd check with you to see if that's your understanding with him before replying all to clarify. thank you! From: Sent: Thursday, May 14, 2020 15:54 To: Cc: EFTA00016437
Subject: Re: Epstein search warrant documents 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. From: Sent: Wednesday, May 13, 2020 12:25 PM To: Cc: •••• 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 us! I was just trying to understand the approach, as well as the timeline. thanks, From: Sent: Tuesday, May 12, 2020 13:03 To: EFTA00016438
Cc: >; >; >; Subject: Re: Epstein search warrant documents 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. 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. From: Sent: Tuesday, May 12, 2020 11:33 AM To: Cc: Subject: RE: Epstein search warrant documents C 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: Sent: Tuesday, May 12, 2020 11:30 To: Cc: >; Subject: RE: Epstein search warrant documents EFTA00016439