| From: | | | | | |
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| To: | (USANYS)" <1 | | | | |
| Cc: a" | NNa
I. | allir
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i | | | |
| 11
Subject: Re: Epstein search warrant documents
Date: Thu, 02 Jul 2020 23:19:03 +0000 | | | | | |
| We haven't but definitely will, thanks. | | | | | |
| Sent from my iPhone | | | | | |
| On Jul 2, 2020, at 19:15, | (USANYS) < | | wrote: | | |
| | Have you run this budget/project by Ed yet? If not, would you mind doing so tomorrow or when you next can. Please
copy me and make clear it is on Epstein/Maxwell. Thanks. | | | | |
From: Sent: Thursday, July 2, 2020 5:11 PM To: (USANYS) Cc: (USANYS) .fl cS;
Subject: RE: Epstein search warrant documents
Following up on the below, I think we've given this our absolute best efforts with FBI — they are now well over a month later than their estimate from April on when we would get the New York materials, they're also past their estimate of getting us the New York materials from just this Monday, and we don't have anything close to an estimate on the USVI materials, which constitute the overwhelming majority of the data and are vastly more voluminous than the New York devices. We have kept pushing the timeline back for this option, hoping that CART will finalize, but I think at this point we should have a vendor do it.
Attached is an estimate we got from BRG, which would get everything to us in under a month, and in Relativity-friendly format, in a range of \$85-135K. BRG has done this for our office multiple times in the past and are very effective and efficient, and they get the materials we need. And most importantly, they estimate they can do it all in less than a month. May we have approval to seek funding for this? The estimate is attached. Thanks very much.
Checking in for the estimate of when we can expect to get all the USVI materials?
thanks,
Okay thanks - good luck with the cardiologist! And if you can let us know tomorrow that would be great. Thanks again.
Subject: RE: Epstein search warrant documents
When Fm in the office tomorrow, I will be better able to estimate. Fm at my cardiologist right now.
NY CART Coordinator Senior Forensic Examiner cell desk
On Jun 29, 2020 12:56 PM, re < > wrote: Great, thanks. Is there even a rough estimate of when we will get the USVI materials? Or an estimate of when you'll be able to see how many items to export, so we'll have a better sense of when we'll get those?
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?
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.
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) < MI> Sent: Monday, June 29, 2020 12:34 To: (USANYS) [Contractor] < =1>, Cc: (USANYS) >; (NY) (FBI) < ) c ›; (NY) (FBI) c >; (USANYS)
I am in the process ofAtoorting 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 I 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.
NY CART Coordinator Senior Forensic Examiner cell desk
Subject: RE: Epstein search warrant documents
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.
< > wrote:
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 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,
Subject: RE: Epstein search warrant documents
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.
Subject: RE: Epstein search warrant documents
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,
On Jun I, 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.
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 | | | |
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| Senior Forensic Examiner | | | |
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| On Jun 1, 2020 4:13 PM, '7 | | < | wrote: |
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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.
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.
Subject: RE: Epstein search warrant documents
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)
- 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) < | > | | |
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| Sent: Thursday, May 14, 2020 15:54 | | | | |
| To: | | | (USANYS) [Contractor] | |
| | | | | |
| Cc: | | >; | | > |
| (NY) (FBI) < | >; | (NY) (FBI) | | |
| Subject: Re: Epstein search warrant documents | | | | |
IM•
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.
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,
| . (NY) (FBI)
From: | | | |
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| Sent: Tuesday, May 12, 2020 13:03 | | | |
| To: | .; | (USANYS) [Contractor) | |
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| Cc: | | | |
| (NY) (FBI) <->, | (NY) (FBI) | | |
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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.
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.
Like said in his earlier email. It will be the raw data and it will be marked so it is easier to attribute it to a particular device. Problem now is how to get the data to since he is teleworking.
NY CART Coordinator Senior Forensic Examiner cell desk
On May 12, 2020 11:15 AM, " ys < I have no doubt you do, but can you please tell us what that plan is? Thanks! > wrote:
Subject: RE: Epstein search warrant documents
I will use the spreadsheet, no problem. and I ironed out all the details. We've got a good plan moving forward that will meet your needs.
NY CART Coordinator Senior Forensic Examiner cell
desk
# On May 12, 2020 10:34 AM, ' ),, < wrote:
, it would be very helpful for us if you could please use the attached spreadsheet in transmitting that info so we make sure we get all the info we need. I think you had previously sent us a list of certain information that unfortunately wasn't helpful for us, so we want to make sure we're all on the same page.
In terms of data transfer, are you just sending a literal copy of all the raw data, and we'll process and upload it on our end? I ask to make sure we don't lose any searchability — when FBI sent versions before, it had already been processed. I think what we talked about on the phone a month ago was getting, for example, data from one device to make sure it transfers correctly, before sending over literally everything — is that still the plan?
thanks,
| From: | (USANYS) [Contractor] | |
|-------|-----------------------------------------------|---|
| | Sent: Tuesday, May 12, 2020 10:27 | |
| To: | | > |
| Cc: | >
(NY) (FBI) < | |
| | Subject: RE: Epstein search warrant documents | |
## Hello M,
Me and just finished our phone call regarding the data. will put together a list of the all of the data and where the data was collected. I will work to send some hard drives to so he can begin to copy the data and send it to us. I will need to figure out a way to get the data off of the hard drives.
Please let us know if there are any questions.
Thank you.
| From: | | | | |
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| Sent: Friday, May 8, 2020 2:15 PM | | | | |
| To: | (NY) (FBI) | | (USANYS) < | |
| I (NY) (FBI) <—>; | | (USANYS) | | |
| Cc: | (USANYS) [Contractor] < | >; | | |
| | >; | | | |
| (FBI) < | | | | |
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Subject: RE: Epstein search warrant documents
Okay thanks — please do let us know if at any point that changes, otherwise we'll look forward to being able to review the returns in early June. Thanks again.
| From: | . (NY) (FBI) < | > | | |
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| | Sent: Friday, May 08, 2020 14:14 | | | |
| To: | (USANYS) < | | | |
| | (NY) (FBI) <->; | | (USANYS) | |
| Cc: | (USANYS) [Contractor] < | | >; | |
| | | | | (NY) |
## (FBI) < , Subject: RE: Epstein search warrant documents
There has been talk of us returning to normal soon, so I don't think it will effect the timeline I initially gave you. If it does, I'll let you know.
NY CART Coordinator Senior Forensic Examiner cell desk
On May 8, 2020 1:58 PM, " < wrote: Understood, thanks—it will be great to get that list on Thursday. As a refresh, the info we are looking for is in the attached spreadsheet template.
On the returns themselves, do the changes you mentioned mean that the estimate of a month from now for complete transmission of the search warrant returns is no longer likely? If so could you please let us know what the current estimate would be, so we can factor that in? Thanks very much.
| From: | . (NY) (FBI) >