From: ' To: ' Subject: RE: Epstein search warrant documents Date: Sat, 04 Apr 2020 17:37:03 +0000 Definitely (and sorry for the delay — we were crashing on a bunch of other stuff the past few days). But I do think it would make sense to have a call, since we haven't gotten any response at all to my email from about a month ago. Whatever time works for you and him this coming week, we'll make work on our end. Thanks. From: Sent: Tuesday, March 31, 2020 14:02 To: Subject: RE: Epstein search warrant documents Glad to hear you are both well. I have no experience with Relativity but we could maybe get a conference call going with and see what we can do? Let me know if you are up for it and when you're available. Thanks, From: ) [mailto: Sent: Tuesday, March 31, 2020 1:02 PM To: Subject: RE: Epstein search warrant documents Hey =, So far so good here, thanks — just trying to deal with the tech issues of working from home (not to mention the inability to interview witnesses!) but really can't complain at all, the girlfriend and I are both healthy and distancing. Hope that's true for you and yours too. In terms of the issues below, unfortunately there isn't any progress — it's not a delay on our end, we've run the taint screen and so the AUSAs and agents all have access on Relativity to the materials that sent over in December. We also sent the privilege taint terms to the agents a couple weeks ago so they could run the screen on whatever programs they may be using — that's attached. We hadn't realized that they were impeded on their review due to any taint issue, we just thought they were using Relativity, same as us. More generally though, the issue we continue to have is the same one since February. We have absolutely no sense of what sent to us — it's not organized or identified by device or even by location, the documents aren't joined with their attachments (their "families" in the terms of doc review), we can't look at native files, etc. It's all the issues from my March 9 email, below, which never responded to. And it's only 1.4 million documents out of what are presumably tens of millions total — we haven't gotten any version of the rest (and don't know exactly what we're missing, because again, we have no way to track what we've been given so far). If (and/or others at CART) are teleworking, it would be great to get help on this, because obviously weeks are going by that we could be using to review. I had been trying to push my chiefs for a meeting in early March but then obviously the world imploded! So not sure what can be done currently, but happy to discuss with anybody that would be useful. thanks as always, EFTA00030309